Hadsell

Hadsell v. United States of America, the Department of Treasury

Good Law
United States District Court, Northern District of CaliforniaFebruary 25, 20225:20-cv-03512California4,185 words

Opinion

Trial Court Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 7 CHRISTOPHER HADSELL, Case No. 20-cv-03512-VKD

Plaintiff, ORDER GRANTING DEFENDANT'S v. MOTION FOR SUMMARY

JUDGMENT

UNITED STATES OF AMERICA, THE DEPARTMENT OF TREASURY BY ITS Re: Dkt. No. 55 AGENCY, THE INTERNAL REVENUE

SERVICE,

13 Defendant. 14 Plaintiff Christopher Hadsell claims that he made valid credit elections to have overpayments of his personal income taxes applied to the following year’s tax liability, but the Internal Revenue Service (“IRS”) improperly treated his credit elections as refunds subject to offset. The United States now moves for summary judgment on the sole remaining claim under 26 U.S.C. § 7433,1 arguing that this Court lacks jurisdiction over Mr. Hadsell’s claim and that the offsets in question did not, in any event, violate that statute or any related regulations. Mr. Hadsell opposes the motion. Upon consideration of the moving and responding papers,2 as well as…

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