Doe v. Internal Revenue Service et al
| John Doe |
| Internal Revenue Service, Department of the Treasury and United States of America |
| 3:2024cv00019 |
| January 8, 2024 |
| US District Court for the Middle District of Tennessee |
| Jeffery S Frensley |
| Eli J Richardson |
| Other Statutes: Administrative Procedures Act/Review or Appeal of Agency Decision |
| 05 U.S.C. § 702 Administrative Procedure Act |
| None |
Docket Report
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This docket was last retrieved on February 27, 2024. A more recent docket listing may be available from PACER.
| Document Text |
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| Filing 29 CERTIFICATE of Service filed by Internal Revenue Service re #27 Brief (non-appeal) filed by Internal Revenue Service. (Bishop, Kyle) |
| NOTICE TO FILER re DE#27 : Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Counsel did not include a certificate of service. Please FILE a conformed Certificate of Service for this document. (mg) |
Filing 28
ORDER: MOTION #25 GRANTED. Consequently, the Initial Case Management Conference is hereby reset to June 11, 2024 at 8:30 a.m. via telephone. All parties shall call 1-877-336-1831, and when prompted for the access code, enter 7039387# to participate. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please call 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 2/26/2024. (mg)
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| Filing 27 BRIEF filed by Internal Revenue Service re #6 Motion for Miscellaneous Relief. (Bishop, Kyle) |
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Filing 26
ORDER: Defendant Internal Revenue Service ("IRS") has filed a "Motion to File Sur-Reply to Respond to New Contentions Contained in Plaintiff's Reply Brief" (Doc. No. #24 , "Motion"). The Motion is GRANTED. IRS shall file a sur-reply responding to Plaintiff's Reply in accordance with the Local Rules on or before March 4, 2024. Signed by District Judge Eli J. Richardson on 2/26/2024. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(mg) Modified on 2/26/2024 (mg).
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| Filing 25 Unopposed MOTION for Extension of Time to File Answer re #1 Complaint,,,, #4 Notice of Case Management Conference , Unopposed MOTION to Continue Case Management Conference by Internal Revenue Service. (Attachments: #1 Attachment Proposed Order)(Bishop, Kyle) |
| Reset Hearing: Initial Case Management Conference by Telephone is reset for 6/11/2024 at 08:30 AM before Magistrate Judge Jeffery S. Frensley. (mg) |
| Filing 24 Unopposed MOTION to Permit Sur-Reply re #22 Reply to Response to Motion, Addressing New Evidence and Argument Contained in Reply Brief by Internal Revenue Service. (Attachments: #1 Attachment Proposed Sur-Reply, #2 Attachment Proposed Order Granting Leave to File Sur-Reply)(Bishop, Kyle) |
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Filing 23
ORDER granting #17 and #18 : Having satisfied the requirements of Local Rule 83.01(b), the Motions for Kyle L. Bishop and Matthew J. Beddingfield to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 02/22/2024. (lh)
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| Filing 22 REPLY to Response to re #6 MOTION TO PROCEED PSEUDONYMOUSLY AND TO FILE UNREDACTED COMPLAINT UNDER SEAL filed by John Doe. (Attachments: #1 Exhibit A - Redacted Declaration of Plaintiff in Support of reply)(Martin, Jerry) |
| Filing 21 SUMMONS returned executed by John Doe. Department of the Treasury served on 1/23/2024. (Martin, Jerry) |
| Filing 20 SUMMONS returned executed by John Doe. Internal Revenue Service served on 1/30/2024. (Martin, Jerry) |
| Filing 19 RESPONSE in Opposition re #6 MOTION TO PROCEED PSEUDONYMOUSLY AND TO FILE UNREDACTED COMPLAINT UNDER SEAL filed by Department of the Treasury, Internal Revenue Service, United States of America. (Jones, Anica) |
| VA State Bar status verified as active for Matthew J. Beddingfield not admitted to this court - Local counsel secured. (mg) |
| Filing 18 MOTION for attorney Matthew J. Beddingfield to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-4009990) by John Doe. (Attachments: #1 Attachment Declaration of M. Beddingfield, #2 Attachment M. Beddingfield Certificate of Good Standing 6th Circuit, #3 Attachment M. Beddingfield Certificate of Good Standing U.S. Tax Court)(Martin, Jerry) |
| Filing 17 MOTION for attorney Kyle L. Bishop to Appear Pro Hac Vice (Fee waived) by Department of the Treasury, Internal Revenue Service, United States of America. (Attachments: #1 Attachment - Certificate of Good Standing)(mg) |
| DC Bar status verified as active for Kyle L. Bishop not admitted to this court. (mg) Modified on 2/22/2024 (af). |
| TN State Bar status verified as active for Anica Clarissa Jones admitted to this court. (mg) |
| Filing 16 SUMMONS Returned Executed as to United States of America c/o Attorney General Garland on 01/23/2024 by John Doe. (Martin, Jerry) |
| Filing 15 SUMMONS Returned Executed as to United States of America c/o U.S. Attorney Leventis on 01/22/2024 by John Doe. (Martin, Jerry) |
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Filing 14
ORDER: MOTION #13 for Extension of Time to File Response/Reply as to #6 MOTION TO PROCEED PSEUDONYMOUSLY AND TO FILE UNREDACTED COMPLAINT UNDER SEAL GRANTED. Response due 02/12/24. Signed by Magistrate Judge Jeffery S. Frensley on 02/01/24. (ad)
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| Filing 13 Unopposed MOTION for Extension of Time to File Response/Reply as to #6 MOTION TO PROCEED PSEUDONYMOUSLY AND TO FILE UNREDACTED COMPLAINT UNDER SEAL , #7 Memorandum in Support by Department of the Treasury, Internal Revenue Service, United States of America. (Attachments: #1 Attachment - Proposed Order)(Jones, Anica) |
| Filing 12 NOTICE by Department of the Treasury, Internal Revenue Service, United States of America - SPECIAL APPEARANCE (Jones, Anica) |
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Filing 11
ORDER granting #9 and #10 : Having satisfied the requirements of Local Rule 83.01(b), the Motions for Steven T. Miller and Dean A. Zerbe to Appear Pro Hac Vice are granted. Signed by Lynda M. Hill, Clerk of Court, on 01/24/2024. (lh)
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| Filing 10 MOTION for attorney Dean A. Zerbe to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3989581) by John Doe. (Attachments: #1 Attachment Declaration of D. Zerbe, #2 Attachment Certificate of Good Standing - 9th Circuit, #3 Attachment Certificate of Good Standing - U.S. Tax Court)(Martin, Jerry) |
| Filing 9 MOTION for attorney Steven T. Miller to Appear Pro Hac Vice (paid $150 PHV fee; receipt number ATNMDC-3989574) by John Doe. (Attachments: #1 Attachment Declaration of S. Miller, #2 Attachment Certificate of Good Standing)(Martin, Jerry) |
| Filing 8 Summons Issued as to Department of the Treasury, Internal Revenue Service, United States of America, U.S. Attorney and U.S. Attorney General. Service package returned to counsel by regular mail. (kc) |
| Filing 7 MEMORANDUM in Support of #6 MOTION TO PROCEED PSEUDONYMOUSLY AND TO FILE UNREDACTED COMPLAINT UNDER SEAL filed by John Doe . (Martin, Jerry) |
| Filing 6 MOTION TO PROCEED PSEUDONYMOUSLY AND TO FILE UNREDACTED COMPLAINT UNDER SEAL by John Doe. (Attachments: #1 Attachment Proposed Order)(Martin, Jerry) |
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Filing 5
ORDER: This case is REFERRED to the Magistrate Judge for customized case management in accordance with Local Rule 16.01 and 28 U.S.C. 636(b)(1)(A). Signed by District Judge Eli J. Richardson on 1/9/2024. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(af)
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| Filing 4 NOTICE of Initial Case Management Conference by Telephone is set for 4/9/2024 at 10:00 AM before Magistrate Judge Jeffery S. Frensley. (kc) |
| Filing 3 NOTICE/INFORMATION regarding Consent of the Parties to the Magistrate Judge. (kc) |
| Filing 2 NOTICE OF ADMINISTRATIVE ORDER NO. 217 to parties re obligation of counsel to keep Court apprised of current contact information. (kc) |
| TN State Bar status verified as active for Jerry E. Martin, Seth Marcus Hyatt admitted to this court. (kc) |
| VA State Bar status verified as active for Dean Zerbe not admitted to this court - Local counsel secured. (kc) |
| NOTICE TO COUNSEL Dean Zerbe, Steven Miller: WITHIN 21 DAYS, counsel shall file a Motion to Appear Pro Hac Vice, a Certificate of Good Standing signed by the Clerk of a United States District Court or a U. S. appellate court where admitted, and pay a fee of $150.00 (LR 83.01(b)). PHV due by 1/30/2024. (kc) |
| DC State Bar status verified as active for Steven Miller not admitted to this court - Local counsel secured. (kc) |
| Filing 1 COMPLAINT against Department of the Treasury, Internal Revenue Service, United States of America (Filing fee $405, Receipt number ATNMDC-3986038), filed by John Doe. (Attachments: #1 Attachment - Civil Cover Sheet, #2 Exhibit A IRS Final Award Determination, #3 Exhibit B IRS Policy Statement 4-27, #4 Exhibit C Excerpt from 2008 Internal Revenue Manual, #5 Exhibit D Excerpt from 2010 Internal Revenue Manual, #6 Exhibit E Excerpt from 2023 Internal Revenue Manual, #7 Exhibit F Preliminary Award Recommendation Letter, #8 Exhibit G Revised PARL Package, #9 Exhibit H 8.2.23 Memo to IRS, #10 Exhibit I Final Award Decision, #11 Exhibit J 2nd Final Award Decision)(kc) (Main Document 1 replaced on 1/9/2024) (kc). (Attachment 1 replaced on 1/9/2024) (kc). (Attachment 2 replaced on 1/9/2024) (kc). (Attachment 3 replaced on 1/9/2024) (kc). (Attachment 4 replaced on 1/9/2024) (kc). (Attachment 5 replaced on 1/9/2024) (kc). (Attachment 6 replaced on 1/9/2024) (kc). (Attachment 7 replaced on 1/9/2024) (kc). (Attachment 8 replaced on 1/9/2024) (kc). (Attachment 9 replaced on 1/9/2024) (kc). (Attachment 10 replaced on 1/9/2024) (kc). (Attachment 11 replaced on 1/9/2024) (kc). |
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