Limits on Government’s Reach
The court stressed that injunctions of this kind are typically reserved for tax professionals engaged in shelters or schemes, not individuals delinquent on personal filings.
“Tellingly, neither situation applies here,” Judge Cardone wrote, noting that the government’s reliance on Internal Revenue Code Section 7402(a) stretched the statute beyond its scope. The code, she explained, empowers courts to enforce tax laws but does not give judges authority to impose forward-looking obligations on taxpayers who failed to comply in the past.
The government, she added, could not point to any precedent to support such a demand.
Silence in the Face of Litigation
The Arandas were served with the suit in November, but neither appeared in court nor filed a single response. Judge Cardone found no evidence suggesting their silence stemmed from mistake or confusion, concluding that default judgment was proper under every factor considered.
Representation
The U.S. government is represented by Ramona Stephens Notinger of the Justice Department’s Tax Division. Counsel for the Arandas could not be identified, and neither they nor the DOJ immediately returned requests for comment.
The case underscores the heavy consequences of ignoring tax obligations — a cautionary tale where silence, in the eyes of the court, became as damning as the debt itself.
