Salman v. Swanson

80-2 U.S.T.C. ¶ 9574 (1980)

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Salman v. Swanson

United States District Court for the District of Nevada
80-2 U.S.T.C. ¶ 9574 (1980)

Facts

The Internal Revenue Service (IRS) notified Salman (plaintiff) of a possible tax deficiency based on the IRS’s review of Salman’s 1976 and 1977 tax returns. The IRS offered Salman the opportunity to meet with it to discuss the issues in an informal conference. Salman accepted the offer but advised the IRS that he intended to be represented by someone who was neither an attorney nor a certified public accountant (CPA) nor an agent who was enrolled to practice before the IRS. Salman also stated that he intended to record the conference and that he would not provide the IRS with any papers at the conference. The IRS responded that its rules prohibited Salman from being represented by someone who was not a lawyer, CPA or enrolled agent and that it was impermissible to record an informal conference. The IRS further stated that based on Salman’s refusal to provide any additional papers, the IRS would not proceed with a conference. Salman then sued Swanson and three other IRS employees (collectively, IRS employees) (defendants), alleging that the IRS employees deprived him of his due-process rights. The IRS employees moved to dismiss the complaint on the ground that, among other things, Salman was not deprived of his due-process rights.

Rule of Law

Issue

Holding and Reasoning (Reed, J.)

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