Murphy v. United States

CourtDistrict Court, E.D. California
DecidedFebruary 18, 2025
Docket1:24-cv-00260
StatusUnknown

This text of Murphy v. United States (Murphy v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murphy v. United States, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 DOLORES J. MURPHY, as Trustee of the No. 1:24-cv-00260-KES-BAM CHARLES M. 12 MURPHYADMINISTRATIVE TRUST, 13 Plaintiff, ORDER DENYING IN PART AND GRANTING IN PART DEFENDANT’S 14 v. MOTION TO DISMISS 15 UNITED STATES OF AMERICA, Doc. 17 16 Defendant. 17 18 Plaintiff Dolores J. Murphy (“Ms. Murphy”), as Trustee of the Charles M. Murphy 19 Administrative Trust (the “Administrative Trust”), brings this claim against the United States of 20 America seeking a refund of tax penalties and related interest that the Internal Revenue Service 21 (“IRS”) imposed for the late filing of the 2016 and 2017 tax returns for the trust. Doc. 1 22 (“Compl.”). Ms. Murphy also seeks a refund of penalties assessed in the 2021 tax year related to 23 the payment of the 2016 and 2017 penalties and declaratory relief that the IRS’s denials of her 24 claims are invalid, null, and void. Id. The government moves to dismiss the refund claim related 25 to the 2016 tax year under Federal Rule of Civil Procedure 12(b)(1), claiming that the 2016 26 refund claim is untimely and thus jurisdictionally barred. Doc. 17-1 (“MTD”). 27 The government moves to dismiss both the 2016 and 2017 claims under Rule 12(b)(6), 28 asserting that Ms. Murphy has not set forth any facts that would constitute reasonable cause for 1 the late filing of the Administrative Trust’s 2016 and 2017 returns and the late payment of its 2 2016 and 2017 taxes. Id. Finally, the government seeks dismissal of the requests for declaratory 3 relief as statutorily barred and dismissal of the claims related to the 2021 tax year as moot or 4 jurisdictionally barred. Id. Ms. Murphy opposed the motion, Doc. 19, and the government 5 replied, Doc. 22 (“Reply”). The Court held oral argument on this matter on November 4, 2024. 6 Doc. 27. Ms. Murphy filed supplemental briefing the same day, Doc. 28, to which the 7 government responded on November 25, 2024, Doc. 29. For the reasons set forth below, the 8 Court denies in part and grants in part the government’s motion to dismiss. 9 I. Background1 10 Ms. Murphy is the surviving spouse of Charles M. Murphy (“Mr. Murphy”), who passed 11 away on November 28, 2016. Compl. ¶¶ 40, 44. Ms. Murphy is the trustee of the Administrative 12 Trust. Compl. ¶ 2. 13 On January 7, 1993, Ms. Murphy and Mr. Murphy created a revocable grantor trust (the 14 “Murphy Family Trust”). Compl. ¶ 41. One of the Murphy Family Trust’s assets was 89,955 15 shares of stock of Murphy Bank, and Ms. Murphy and Mr. Murphy were treated as the owners of 16 the stock for income tax purposes. Compl. ¶ 42. Ms. Murphy and Mr. Murphy employed a 17 certified public accountant, Mr. Chaltraw, to provide tax advice and prepare federal and state 18 income tax returns for Murphy Bank, Ms. Murphy, and Mr. Murphy. Compl. ¶ 43. Following 19 Mr. Murphy’s death, Mr. Chaltraw “continued to be the certified public accountant for Murphy 20 Bank, [Ms. Murphy], and the Administrative Trust” and “as such, provided tax advice to and 21 prepared Federal and California income tax returns for them.” Compl. ¶ 45. 22 As he had for years past, Mr. Chaltraw prepared a federal and state income tax return for 23 1 This recitation of facts is mostly taken from Ms. Murphy’s complaint. See Compl. For 24 purposes of a Rule 12(b)(6) motion to dismiss, the allegations in the complaint are assumed to be true. See Hishon v. King & Spalding, 467 U.S. 69, 73 (1984). However, to the extent the 25 government’s 12(b)(1) motion mounts a factual attack on jurisdiction, “the district court may review evidence beyond the complaint” to resolve the factual dispute and resolve the 26 jurisdictional question. Safe Air for Everyone v. Meyer, 373 F.3d 1035, 1039 (9th Cir. 2004). 27 Thus, some disputed facts from the government’s moving papers are also contained within this recitation to the extent they relate to the Rule 12(b)(1) motion. 28 1 Murphy Bank, Ms. Murphy, and Mr. Murphy for the 2016 tax year and for Murphy Bank and Ms. 2 Murphy for the 2017 tax year. Compl. ¶¶ 46, 48, 54, 56. The chief financial officer of Murphy 3 Bank and Ms. Murphy provided Mr. Chaltraw with all the information and documents requested 4 by him to prepare the returns. Compl. ¶¶ 47, 49, 55, 57. Ms. Murphy and the chief financial 5 officer of Murphy Bank met with Mr. Chaltraw so that he could review the tax returns with them, 6 advise them of any balance due, and obtain Ms. Murphy’s authorization to electronically file the 7 returns. Compl. ¶¶ 50, 58. She “did not read or thoroughly review” the forms; rather, she “relied 8 on [their] long-term certified public accountant[] to prepare complete and accurate Federal and 9 California income tax returns for [them].” Compl. ¶¶ 50, 58. 10 In February 2019, Ms. Murphy’s tax counsel discovered that, following Mr. Murphy’s 11 death, no tax returns had been filed for the Administrative Trust for the 2016 or 2017 tax years. 12 Compl ¶¶ 51-53. Rather, some of the “S corporation items of Murphy Bank . . . allocable to the 13 Murphy Bank Stock held by the Murphy Family Trust” and other income, gains, losses, 14 deductions, and credits of the Administrative Trust were incorrectly attributed to the individual 15 tax returns of Mr. and/or Ms. Murphy, and the gross income allocable to Ms. Murphy in the form 16 of distributions from the Administrative Trust following Mr. Murphy’s death were not included 17 on her tax returns. Compl ¶¶ 51-53. Ms. Murphy alleges that these errors occurred “[d]ue to [Mr. 18 Chaltraw’s] erroneous tax advice to [Ms. Murphy] individually, as the executor of Mr. Murphy’s 19 estate, and as Trustee of the Administrative Trust.” Compl. ¶ 61. Thereafter, Mr. Chaltraw 20 remedied the errors with the tax returns filed by Murphy Bank, Ms. Murphy, and Mr. Murphy for 21 the relevant years and prepared the tax returns for the Administrative Trust. Compl. ¶ 62.; Doc. 22 19-1 at 37.2 23 On July 15, 2020, Ms. Murphy, as trustee of the Administrative Trust, filed late the 24 Administrative Trust’s U.S. Income Tax Return for Estates and Trusts (Form 1041) and the 25 Administrative Trust’s U.S. Information Return Trust Accumulation of Charitable amounts (Form 26 1041-A) for the 2016 tax year. Compl. ¶ 5. Along with the 1041 form, she submitted a check for 27 2 Mr. Chaltraw’s reasonable cause statement is incorporated by reference into Ms. Murphy’s 28 complaint. Compl. ¶ 67. 1 the tax and accrued interest due for the 2016 tax year and a letter requesting that the IRS forego 2 assessing any penalties against Ms. Murphy for late filing of the return and late payment of the 3 taxes due, claiming that the lateness was due to reasonable cause and not willful neglect. Compl. 4 ¶¶ 5-6. In support of the letter requesting a finding of reasonable cause, Ms. Murphy filed 5 declarations by her and her accountant. Compl. ¶ 6. Similarly, on July 31, 2020, Ms. Murphy 6 filed late tax return Forms 1041 and 1041A on behalf of the Administrative Trust for the 2017 tax 7 year. As with the 2016 claim, with the filing she included a letter requesting that no late penalties 8 be assessed and included the declarations by her and her accountant as support. Compl. ¶¶ 8-10. 9 Around September 20, 2021, the IRS processed the 2016 Form 1041-A and assessed late 10 filing penalties of $8,270.00 under 26 U.S.C. § 6652. Compl. ¶¶ 13-14. Around November 15, 11 2021, the 2016 Form 1041 was processed and the IRS assessed a late filing penalty of $9,523.35 12 under 26 U.S.C.

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Murphy v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murphy-v-united-states-caed-2025.