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16-2000 - United States of America (IRS) et al v. Canada


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16-2000 - United States of America (IRS) et al v. Canada
May 8, 2017
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MEMORANDUM OPINION AND ORDER: The Court AFFIRMS the bankruptcy court's order sustaining William R. Canada, Jr's objection to, and disallowing the IRS's claim for, civil penalties for failing to register the Heritage Transactions as tax shelters. Additionally, as noted above, Canada's 11 motion to strike is DENIED. Because the Court AFFIRMS the bankruptcy court, it does not reach Canada's provisional cross-appeal. Accordingly, this appeal is DISMISSED. (Ordered by Judge Jane J. Boyle on 5/8/2017) (twd)