Gaynor v. Empirian Village of Maryland, LLC, No. 1:2022cv01940 - Document 33 (D. Md. 2023) se opn om the District of Maryland US Feral District Court
Contents:
- CROWLEY V. GAYNOR ET AL
- GAYNOR V. USA, NO. 1:2019CV00053 - DOCUMENT 28 (FED. CL. 2020)
- GAYNOR V. PAYNE
- MOSW JURY RUL NOT GUILTY FOR CONFSED MURRER OF GAY MAN
- GAYNOR V. EMPIRIAN VILLAGE OF MARYLAND, LLC, NO. 1:2022CV01940 - DOCUMENT 33 (D. MD. 2023)
CROWLEY V. GAYNOR ET AL
Docket for Crowley v. Gaynor, 1:10-cv-12045 — Brought to you by Free Law Project, a non-prof dited to creatg high qualy open legal rmatn. * gaynor v cowley *
Gaynor, seeks the refund of a portn of civil penalti that the Internal Revenue Service (“IRS”) asssed agast him for his failure to ply wh reportg obligatns related to his terts certa foreign rporatns. Gaynor has never paid full the penalti asssed agast him for the years 2002 through 2009, or for the years 2011 through 2015. Gaynor has paid full the penalti asssed agast him for 2010 and has sought a refund om the IRS for that full payment.
Gaynor’s payment full and acpanyg refund requt for the 2010 penalti are sufficient to nfer jurisdictn upon this Court to nsir Mr.
Gaynor never received a notice of disallowance om the IRS for his claimed 2010 refund, he was required to wa six months after filg a refund claim wh the IRS before iatg his su. Gaynor first filed the stant actn prr to havg satisfied any of the jurisdictnal prerequis for any year (cludg 2010), and he may not circumvent the mandatory six-month wag perd for the 2010-related claims via the FAC or by havg that wag perd lapse while the FAC is pendg.
GAYNOR V. USA, NO. 1:2019CV00053 - DOCUMENT 28 (FED. CL. 2020)
Parti, docket activy and news verage of feral se Crowley v. Gaynor et al, se number 1:10-cv-12045, om Massachetts Court. * gaynor v cowley *
Gaynor further seeks a claratn that all penalti asssed agast him were “unlawful, ” and that the penalti asssed for the years 2002–2005 were improper due to the applible statute of limatns ntaed I. Gaynor prevly assisted managg his father’s vtments, which clud, among other assets, a Swiss vtment acunt managed by Aquila & Co., AG, Zurich, Swzerland (“Aquila”).
Gaynor was not aware of Sonosi’s transfer to Centapriv or even Sonosi’s existence altogether until Aquila, the Swiss vtment manager of Sonosi, so rmed Mr. Gaynor that Runr was created as a separate enty, based Zug, Swzerland, for the purpose of licensg an tomobile which was to be driven by Mr.
GAYNOR V. PAYNE
GAYNOR v. USA, No. 1:2019cv00053 - Document 28 (Fed. Cl. 2020) se opn om the US Court of Feral Claims * gaynor v cowley *
Gaynor alleg that “[a]s was the se wh Sonosi, Platiff was assured by Centrapriv that Runr was a Swiss rporatn as to which Platiff had no [IRS] reportg rponsibili. Gaynor alleg, however, that at that pot – even after learng of IRS reportg requirements for the Swiss bank acunts – Mr.
Gaynor received a notice om the IRS ptned “Failure to File Form 5471” for Sonosi (the “Sonosi Failure Notice”), dated May 8, 2017.
Gaynor matas that was not until he received the Sonosi Failure Notice that he learned of a Form 5471 filg rponsibily regardg Sonosi. Gaynor transmted Form 5471 for Sonosi to the IRS for the years 2004 through 2015, acpanied by a Statement of Reasonable Cse, explag his failure to file the forms a timely manner. Gaynor then received a notice om the IRS which was entled “Failure to File Form 5471” for Runr (“Runr Failure Notice”), dated September 12, 2017.
MOSW JURY RUL NOT GUILTY FOR CONFSED MURRER OF GAY MAN
Gaynor v. Payne * gaynor v cowley *
Gaynor alleg that he first beme aware that he also was required to file Form 5471 for Runr when he received the Runr Failure Notice. Gaynor transmted Form 5471 for Runr verg the years 2002 through 2015, once aga acpanied by a Statement of Reasonable Cse.
Gaynor for each of the years 2004 through 2015 for which he had failed to subm the required forms for Sonosi, for a total of $120, 000. Gaynor transmted a Prott of the Sonosi Form 5471 penalti to the IRS, as well as a Requt for Consiratn by the Office of Appeals. Gaynor for each of the years 2002 through 2015 for which he had failed to subm the required forms for Runr, for a total of $140, 000 (i.
Gaynor had done for Sonosi, he transmted to the IRS a Prott of the Runr Form 5471 penalti, as well as a Requt for Consiratn by the IRS Office of Appeals. Gaynor did so through a number of different lump-sum payments, of varyg amounts, and at different tim, related to Mr. Gaynor “assumed that, as Runr was effectively a subsidiary of Sonosi, no Form 5471 was required to be filed for Runr.
GAYNOR V. EMPIRIAN VILLAGE OF MARYLAND, LLC, NO. 1:2022CV01940 - DOCUMENT 33 (D. MD. 2023)
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Gaynor noted that as of the date of filg of his FAC, he had not yet received a rponse om the IRS Office of Appeals to eher of his Requts for Consiratn. Gaynor’s $1, 200 payment was acpanied by a letter ditg that he wished for that lump-sum payment to be applied towards the penalti that were asssed agast him (based on his tert Sonosi) for the years 2004-2015, allotns of $100 for each year, rpectively. Gaynor’s $1, 400 payment was acpanied by a letter askg for that lump-sum payment to be applied towards the penalti that were asssed agast him (based on his tert Runr) for the years 2002-2015, alloted at $100 for each year.
Gaynor that the IRS had “applied a Form 1040 overpayment for the year 2004 the amount of $1, 200 to the civil penalty owed for December 31, 2004. Gaynor ntends that he sentially ma an addnal $1, 200 payment December 2018, for the penalti asssed agast him 2004.
Gaynor fully paid the 2010 penalti asssed agast him, he also sent letters to the IRS which clud IRS Form 843 (Claims for Refund).