United States of America v. Snyder, No. 2:2024cv00211 - Document 7 (D. Nev. 2024)
Court Description: ORDER granting 6 Stipulated/Consent Judgment for permanent injunction. Signed by Judge Cristina D. Silva on 5/6/2024. (Copies have been distributed pursuant to the NEF - MAM)
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United States of America v. Snyder 1 2 3 4 5 6 7 Doc. 7 David A. Hubbert Deputy Assistant Attorney General Tijuhna A. Green (TXBN 24106025) Trial Attorney, Tax Division U.S. Department of Justice P.O. Box 683 Washington, D.C. 20044 202-616-3340 202-307-0054 (f) Tijuhna.A.Green@usdoj.gov Western.taxcivil@usdoj.gov 8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 9 10 11 UNITED STATES OF AMERICA, Plaintiff 12 13 14 15 16 17 18 Case No. 2:24-cv-00211-CDS-DJA ORDER GRANTING STIPULATION FOR ENTRY OF PERMANENT INJUNCTION ORDER v. DENA LOUISE SNYDER, Defendant Plaintiff, the United States of America, and Defendant Dena Louise Snyder, jointly move for entry of the attached Consent Judgment and Order for Permanent Injunction. The United States brought this suit to enjoin Snyder from directly or indirectly acting a tax return 19 preparer. ECF No. 1. Snyder admits that this Court has jurisdiction over her and the subject matter of 20 this action. Snyder stipulates to the facts alleged in the United States’ Complaint. ECF No. 1. Snyder 21 consents to the entry of judgment and injunction against her under Federal Rule of Civil Procedure 65 22 and 26 U.S.C. §§ 7402(a), 7407, and 7408. Snyder further waives any right to appeal from this 23 Judgment and Order of Permanent Injunction. 24 Snyder also agrees that this Court shall retain jurisdiction over her for the purpose of 25 implementing and enforcing this Stipulated Order of Permanent Injunction. Snyder further understands 26 27 28 1 Dockets.Justia.com 1 that if she violates this Stipulated Permanent Injunction Order, she may be found in contempt of 2 court and may be sanctioned for that. 3 The Parties agree that the entry of this permanent injunction does not preclude the Internal 4 Revenue Service in any way from assessing or collecting taxes, penalties, and interest against 5 Snyder, and also does not preclude Snyder from contesting her liability for such taxes, penalties, and 6 interest. 7 8 9 10 11 12 The Parties further agree that the entry of the permanent injunction is appropriate for the enforcement of the internal revenue laws. Accordingly, it is hereby ORDERED, ADJUDGED, and DECREED that: 1. This Court has jurisdiction over this action and the Defendant pursuant to 26 U.S.C. §§ 7402(a), 7407, and 7408 as well as 28 U.S.C. §§ 1340 and 1345. 2. A PERMANENT INJUNCTION IS HEREBY ENTERED against Defendant Dena L. Snyder 13 from the date of this Order, and it is hereby ORDERED, ADJUDGED, AND DECREED that 14 Defendant Dena L. Snyder is permanently enjoined from: 15 a. Preparing, assisting in the preparation of, or directing the preparation of any federal tax 16 returns, amended returns, or other federal tax-related documents or forms, including any 17 electronically submitted tax returns or tax-related documents, for any person or entity 18 other than herself; 19 b. Filing, assisting in the filing of, or directing the filing of federal tax returns, amended 20 returns, or other tax-related documents or forms, including any electronically submitted 21 tax returns or tax-related documents, for any person or entity other than herself; 22 c. Owning, operating, managing, assisting, investing in, receiving fees or remuneration 23 from, controlling, licensing, consulting with, franchising, or working at a business that 24 prepares or assists in the preparation of tax returns, amended returns, or other tax-related 25 26 27 28 2 1 documents or forms, including any electronically submitted tax returns or tax-related 2 documents; 3 d. Employing any person to prepare, file or assist in the preparation of filing of any federal 4 tax returns, amended returns, or other tax-related documents or forms, including any 5 electronically submitted tax returns or tax-related document for any person or entity other 6 than herself; e. Training, advising, counseling, instructing, teaching, or creating or providing any person 7 8 with cheat sheets, memoranda, directions, instructions, or manuals pertaining to the 9 preparation of federal tax returns; f. Maintaining, holding, using, obtaining, assigning, transferring, leasing, selling, or 10 11 providing in any way to any individual or entity: (1) a personal or business Preparer tax 12 identification number (PTIN); (2) a personal or business Electronic Filing Identification 13 Number (EFIN); (3) any other federally issued identification number(s) to prepare or file 14 federal income tax returns; (4) a list of customers or any other customer information; or 15 (5) any proprietary information pertaining to their tax preparation or tax software 16 licensing/selling businesses; 17 g. Providing office space, equipment, software, or services for, or in any other way 18 facilitating, the work of any person or entity that is in the business of preparing or filing 19 federal tax returns or other federal tax documents or forms for others or representing 20 persons before the IRS;1 21 22 23 24 25 26 27 28 1 Dena Snyder is permitted to sublease the commercial office space located at 2670 Chandler Ave. Ste. 2, Las Vegas, NV 89120 until December 31, 2025 or earlier should the lease be terminated prior to that date, provided that she (1) does not profit from subleasing the office space and (2) does not receive any payments in connection with the operation of a tax-related business. 3 1 h. Working in the same office or office suite that also contains any part of a business whose 2 activity at that office or office suite is to file, prepare, advise, or assist in the preparation 3 of documents relating to a matter material to the internal revenue laws, including federal 4 tax returns, amended federal tax returns and related documents, for any person for 5 compensation; 6 i. Referring any person to a tax preparation firm or to a tax return preparer, or otherwise 7 suggesting that a taxpayer use any given tax preparation firm or tax return preparer; 8 j. Advertising tax return preparation services through any medium, including print, online, 9 and social media; 10 k. Representing persons before the Internal Revenue Service; 11 l. Engaging in any conduct or activity subject to penalty under 26 U.S.C. §§ 6694, 6695, 12 13 14 15 6700, 6701, or any other penalty provision in the Internal Revenue Code; m. Otherwise engaging in conduct that substantially interferes with the proper administration and enforcement of the internal revenue laws. 3. It is further ORDERED, ADJUDGED, AND DECREED that Snyder shall: 16 a. Within 60 days of this Court’s Order mail, at her own expense, by first class U.S. mail to 17 the last known address and, if an email address is known, by email, all persons for whom 18 she prepared or assisted in preparing federal tax returns during the last three years, to 19 inform them of the permanent injunction entered against her; and include a copy of the 20 Court’s Permanent Injunction Order, but no other documents or enclosures unless agreed 21 to by counsel for the United States or the Court, and file with the Court a sworn 22 certificate stating that she has complied with this requirement; and 23 b. Defendant shall produce to counsel for the United States, within sixty (60) days of this 24 Court’s Order, a list that identifies by name, Social Security number, address, email 25 26 27 28 4 1 Respectfully submitted, 2 DAVID A. HUBBERT DEPUTY ASSISTANT ATTORNEY GENERAL 3 4 Date: May 3, 2024 5 6 7 8 9 Attorneys for the United States of America 10 11 12 13 s/Tijuhna A. Green TIJUHNA A. GREEN Trial Attorney, Tax Division U.S. Department of Justice P.O. Box 683 Washington, D.C. 20044 202-616-3340 202-307-0054 (f) Tijuhna.A.Green@usdoj.gov Date: April 30, 2024 *scanned signature page attached Dena Snyder 244 Shoshone Ln. Henderson, NV 89015 Defendant 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6
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