United States v. Stover, Jr., No. 10-3012 (8th Cir. 2011)
Annotate this CaseThe United States brought this civil action under 26 U.S.C. 7408 to enjoin defendant from promoting several fraudulent tax schemes. After a court trial, the district court permanently enjoined defendant from promoting his schemes, ordered him to advise the IRS of any tax arrangements or business entities formed at his discretion, and required him to provide a copy of its order to his clients. On appeal, defendant argued that the injunction was not supported by adequate factual findings and legal conclusions, and that it was overbroad, an impermissible delegation of Article III power, and an unconstitutional prior restraint. The court rejected defendant's hypertechnical criticisms of the district court's order where section 6700 was a linguistically complex and intricate statute and where the district court need not include the entire statutory language in each of its findings and conclusions. Therefore, the court held that the district court's exhaustive order more than satisfied each of the requirements in section 6700 and affirmed the judgment of the district court.
Court Description: Civil case - Injunctions - 26 U.S.C. Sec. 7408. District court did not err in permanently enjoining Stover from promoting several fraudulent tax schemes; injunction was supported by the record and adequate fact findings; injunction was not overbroad, an impermissible delegation of Article III power or an unconstitutional prior restraint.
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