United States of America v. Moore, Ingram, Johnson & Steele, LLP
Petitioner: United States of America
Respondent: Moore, Ingram, Johnson & Steele, LLP
Case Number: 1:2020cv02413
Filed: June 5, 2020
Court: US District Court for the Northern District of Georgia
Presiding Judge: Leigh Martin May
Referring Judge: Linda T Walker
Nature of Suit: Taxes
Cause of Action: 26 U.S.C. § 7402
Jury Demanded By: None
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Docket Report

This docket was last retrieved on August 3, 2020. A more recent docket listing may be available from PACER.

Date Filed Document Text
August 3, 2020 Filing 20 OBJECTIONS to #18 Report and Recommendation filed by United States of America. (Applegate, Daniel)
July 21, 2020 Opinion or Order Filing 19 ORDER for Service of #18 Final Report and Recommendation, by Magistrate Judge Linda T. Walker. Each party may file written objections to the Report & Recommendation within 14 days of service. If no objections are filed, the Report & Recommendation may be adopted as the opinion and order of the District Court. Signed by Magistrate Judge Linda T. Walker on 7/20/2020. (tmf)
July 21, 2020 Opinion or Order Filing 18 FINAL REPORT AND RECOMMENDATION re #1 Petition to Enforce IRS Summons, filed by United States of America. The undersigned RECOMMENDS that the Petition be GRANTED in part and DENIED in part. As explained above, the undersigned RECOMMENDS that the Petition be DENIED as to the specific documents Respondent itself has already produced, but that the Petition otherwise be GRANTED. The undersigned RECOMMENDS that a special master be appointed to resolve discovery disputes between the parties. Additionally, because allocating the payment of the special master among the parties depends on issues not yet fully developed, the undersigned further RECOMMENDS that the Court withhold ruling on that issue at this time. The Clerk is directed to terminate the reference to the undersigned. See order for further specifics. Signed by Magistrate Judge Linda T. Walker on 7/20/2020. (tmf)
July 13, 2020 Opinion or Order Filing 17 FIFTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 7/10/2020 (mmc) (ADI)
July 2, 2020 Filing 16 TRANSCRIPT of F.T.R. Tape-Recorded Magistrate Proceedings held on 6/18/2020, before Judge Linda T. Walker. Court Reporter Montrell Vann. Transcript may be purchased through the Court Reporter at Montrell_Vann@gand.uscourts.gov. Redaction Request due 7/23/2020. Redacted Transcript Deadline set for 8/3/2020. Release of Transcript Restriction set for 9/30/2020. (Attachments: #1 Appendix Notice of Filing of Transcript) (mv)
July 2, 2020 Opinion or Order Filing 15 FOURTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 07/01/2020. (ddm) (ADI)
June 18, 2020 Filing 14 Minute Entry for proceedings held before Magistrate Judge Linda T. Walker: Show Cause Hearing held on 6/18/2020. The parties appeared before the court for a show cause hear re attorneys' fees. The court heard oral arguments from the parties and advised that it would issued a report and recommendation at a later date. (Tape #FTRGOLD)(tmf)
June 12, 2020 Filing 13 RESPONSE re #12 Response (Non-Motion), filed by United States of America. (Applegate, Daniel)
June 5, 2020 Case reported statistically. Matter transferred from 1:20-mi-00021. (tmf)
June 4, 2020 Filing 12 RESPONSE re #1 Petition to Enforce IRS Summons, filed by Moore, Ingram, Johnson & Steele, LLP. (Attachments: #1 Exhibit 1 - Affidavit of Matthew J. Howard, #2 Exhibit 2 - IRS District Counsel Diana Wells September 13, 2019 Letter, #3 Exhibit 3 - MIJS September 26, 2019 Letter to IRS District Counsel Diana Wells, #4 Exhibit 4 - IRS Summonses to CRI, Milliman and Pinnacle, #5 Exhibit 5 - IRS Form 8886 and IRS Form 8886 Instructions)(Daxe, Jeffrey)
June 4, 2020 Filing 11 NOTICE Of Filing Western District of Kentucky Cases Docket and Certain Docket Entries by Moore, Ingram, Johnson & Steele, LLP (Daxe, Jeffrey)
June 4, 2020 Filing 10 NOTICE Of Filing Eastern District of Kentucky Cases Docket and Certain Docket Entries by Moore, Ingram, Johnson & Steele, LLP (Daxe, Jeffrey)
June 4, 2020 Filing 9 NOTICE Of Filing Original Affidavit of Matthew J. Howard In Support of Respondent's Response to Petitioner's Petition to Enforce Internal Revenue Service Summons by Moore, Ingram, Johnson & Steele, LLP re #8 Answer to Petition to Enforce IRS Summons (Attachments: #1 Affidavit Affidavit of Matthew J. Howard, #2 Attachment A - Rob Walling Affidavit, #3 Attachment B - Notice 2016-66 - Transaction of Interest, #4 Attachment C - 2018 and 2019 Dirty Dozen List, #5 Attachment D - Memo Distinguishing Avrahami, #6 Attachment E - IRS Notice of Audit, #7 Attachment F - MIJS IDR, #8 Attachment G - CL to IDR Response 6-25-18, #9 Attachment H - Redacted No Change Letters, #10 Attachment I - Redacted Complaint Against Nikki Wells, #11 Attachment J - MIJS Summons, #12 Attachment K - MIJS Objections and Responses to IRS Summons, #13 Attachment L - ED and WD of KY Orders Upholding Attorney-Client Privilege, #14 Attachment M - ED and WD of KY US Objections to Order, #15 Attachment N - ED and WD of KY Orders Upholding Recommendation, #16 Attachment O - ED of KY IRS Notice of Appeal and Voluntary Dismissal)(Daxe, Jeffrey)
June 3, 2020 Filing 8 Affirmative Defenses and ANSWER to #1 Petition to Enforce IRS Summons by Moore, Ingram, Johnson & Steele, LLP.(Daxe, Jeffrey) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
June 2, 2020 Filing 7 Corporate Disclosure Statement by Moore, Ingram, Johnson & Steele, LLP by Moore, Ingram, Johnson & Steele, LLP.(Daxe, Jeffrey)
June 2, 2020 Filing 6 NOTICE of Appearance by Kenneth Hall on behalf of Moore, Ingram, Johnson & Steele, LLP (Hall, Kenneth)
June 2, 2020 Filing 5 NOTICE of Appearance by Jeffrey Alan Daxe on behalf of Moore, Ingram, Johnson & Steele, LLP (Daxe, Jeffrey)
May 19, 2020 Filing 4 CERTIFICATE OF SERVICE re #3 Order to Show Cause, #1 Petition to Enforce IRS Summons, filed by United States of America (served on May 15, 2020) (Applegate, Daniel)
May 14, 2020 Opinion or Order Filing 3 ORDER TO SHOW CAUSE Show Cause Hearing set for 6/18/2020 at 09:30 AM in ATLA Courtroom 1860 before Magistrate Judge Linda T. Walker, for Moore, Ingram, Johnson & Steele, LLP to show cause why it should not be compelled to obey the Internal Revenue Service issued to it on April 16, 2019. Signed by Magistrate Judge Linda T. Walker on 5/14/20. (eop)
March 24, 2020 Opinion or Order Filing 2 GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 03/16/20.(aaq)
March 2, 2020 Submission of #1 Petition to Enforce IRS Summons, to Magistrate Judge Linda T. Walker. (eop)
February 4, 2020 Filing 1 PETITION to Enforce IRS Summons filed by United States of America. (Attachments: #1 Exhibit -1 -Declaration of Tammy R., #2 Exhibit -2 -IRS Summmons Issued, #3 Civil Cover Sheet, #4 Text of Proposed Order)(eop) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form.

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Petitioner: United States of America
Represented By: Daniel A. Applegate
Represented By: Neeli Ben-David
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Respondent: Moore, Ingram, Johnson & Steele, LLP
Represented By: Jeffrey Alan Daxe
Represented By: Kenneth Hall
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