Crowley v. Gaynor et al

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

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 V. USA, NO. 1:2019CV00053 - DOCUMENT 28 (FED. CL. 2020)

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 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 V. PAYNE

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 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.

MOSW JURY RUL NOT GUILTY FOR CONFSED MURRER OF GAY MAN

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.

GAYNOR V. EMPIRIAN VILLAGE OF MARYLAND, LLC, NO. 1:2022CV01940 - DOCUMENT 33 (D. MD. 2023)

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.