Galliani
United States v. Galliani
Opinion
trial_court Opinion
1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 Case Nos. 22-cv-03365-JSC (Lead) 7 UNITED STATES OF AMERICA, 23-cv-02558-JSC Plaintiff, 8 v. ORDER RE: MOTION TO STAY 9
10 RAYMOND A. GALLIANI, Defendant. 11 12 UNITED STATES OF AMERICA Plaintiff and Counterdefendant, 13 v. 14
15 RAYMOND A. GALLIANI, as personal representative of the ESTATE OF SHARON 16 GALLIANI, Defendant and Counterclaimant. 17
18 The government filed actions against Raymond Galliani and the Estate of Sharon 19 Galliani—Mr. Galliani’s late wife (collectively “Defendant”)—alleging they willfully failed to 20 report their interests in foreign accounts (the “FBAR cases”). Later, Defendant filed a petition to 21 the Tax Court, contesting the Internal Revenue Service’s notice of deficiency regarding their tax 22 liabilities. Pending before the Court is Defendant’s motion to stay the FBAR cases pending 23 resolution of the Tax Court Case. Because Defendant fails to demonstrate hardship or inequity 24 that outweighs the potential harm a stay could cause the government, the Court…