Salcida v. United States

CourtUnited States Court of Federal Claims
DecidedJanuary 30, 2026
Docket23-1048
StatusUnpublished

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

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Salcida v. United States, (uscfc 2026).

Opinion

In the United States Court of Federal Claims No. 23-1048 (Filed: January 30, 2026) (NOT FOR PUBLICATION)

* * * * * * * * * * * * * * * * ** * * JOHN SALCIDA, * * Plaintiff, * * v. * * THE UNITED STATES, * * Defendant. * * * * * * * * * * * * * * * * * * ** *

John A. Salcida, pro se, of San Diego, CA.

Elizabeth Villareal, Trial Attorney, Court of Federal Claims Section, Tax Division, U.S. Department of Justice, with whom were David A. Hubert, Deputy Assistant Attorney General, David I. Pincus, Chief of Court of Federal Claims Section, all of Washington, D.C., for Defendant.

MEMORANDUM OPINION AND ORDER

SOMERS, Judge.

After this Court dismissed his case on June 13, 2024, Plaintiff John Salcida filed two motions for reconsideration and a motion for costs and fees. Specifically, Plaintiff challenges this Court’s determination that he failed to state a claim regarding COVID-19 refunds and an education tax credit allegedly owed to him by the IRS. In response, the government opposed both motions for reconsideration and the motion for costs and fees. For the reasons explained below, the Court denies Plaintiff’s motions for reconsideration and grants in part Plaintiff’s motion for costs and fees.

BACKGROUND

A. Plaintiff’s Initial Claim

On July 7, 2023, Plaintiff filed a complaint in this Court alleging that the Internal Revenue Service (“IRS”) failed to disburse two COVID-19 tax refunds and an education tax credit to him. ECF No. 1. The IRS had allegedly mailed Plaintiff two letters concerning an education credit and a COVID-19 refund, informing him that he was entitled to $1,800 for each. ECF No. 1-1 at 2, 5. However, according to Plaintiff, he only received one check for $1,800, rather than the two he expected. ECF No. 1 at 1–2. Plaintiff later received an IRS letter adjusting the education credit from $1,800 to $1,000, but he allegedly never obtained the reduced refund. ECF No. 9 at 2. The government moved to dismiss Plaintiff’s claim on the basis that the IRS had already paid Plaintiff all that it owed him. See generally ECF No. 17. The IRS provided Plaintiff’s account transcripts in support of its motion and stated that it had paid Plaintiff $1,800 total in COVID-19 refunds in 2020—divided into a $1,200 and a $600 payment—but did not owe him a $1,800 education credit. Id. at 3–5; ECF No. 17-1 at 5–8.

In response to the government’s motion, Plaintiff argued that the IRS transcripts the government provided, which showed several refunds followed by cancellations, were unreliable. ECF No. 20 at 2. Plaintiff then filed an amended complaint on October 24, 2023, reiterating that the IRS owed him the education credit and claiming another COVID-19 refund of $1,800. ECF No. 22 at 2–3. The government moved to dismiss Plaintiff’s amended complaint on November 7, 2023. See generally ECF No. 23. Therein, the government explained that the IRS had sent Plaintiff a second COVID-19 refund of $1,400 in 2021 but that by law Plaintiff was only permitted a refund of up to $1,400—not the $1,800 that Plaintiff claimed. Id. at 3–4; ECF No. 23-1 at 11. The government also stated that Plaintiff received an education credit plus interest for 2022, but under law, the credit could not exceed $1,000. ECF No. 23 at 5–6; ECF No. 23-1 at 14 (showing $1,033.87 issued October 16, 2023). Thus, in total, the IRS claimed that it had paid Plaintiff $1,800 and $1,400 for two COVID-19 refunds in 2020 and 2021, respectively, and a $1,000 education credit in 2022. ECF No. 23-1 at 11, 14; ECF No. 17 at 3–4; ECF No. 23 at 6.

In this motion to dismiss, the government referenced Plaintiff’s 2020-2022 account transcripts, which were accompanied by a declaration from an IRS attorney as to their accuracy. See generally ECF No. 23; ECF No. 23-1 at 1–3 (declaration of Jennifer Brooker). Despite the tax transcript and supporting declaration, on February 6, 2024, the Court ordered the government to provide supplemental briefing on whether Plaintiff had received the $1,400 COVID-19 refund because the 2021 transcript showed an account balance of -$1,400, among several credits and cancellations. ECF No. 29 at 1 & n.2. In reference to the $1,000 education credit, the Court requested an updated 2022 transcript because the Court was concerned that it may have the same issues (several refunds followed by cancellations) as the 2021 transcript, suggesting that Plaintiff might not have received the $1,000 education credit because it had been cancelled. Id. at 1–2.

On February 29, 2024, the government filed a supplemental brief explaining that the 2021 transcript showed a cancelled $1,400 COVID-19 tax payment because it was a duplicate of the $1,400 COVID-19 refund that Plaintiff had already received. ECF No. 30 at 2; ECF No. 30- 1 at 5–7. The government also provided an updated 2022 transcript, which showed that the IRS had not cancelled the $1,000 education credit payment. ECF No. 30 at 3; ECF No. 30-1 at 11– 12.

Based on the government’s supplemental briefing, the Court issued an opinion on June 13, 2024, granting the government’s motion to dismiss. See generally ECF No. 32. The Court found that Plaintiff failed to state a claim under Rule 12(b)(6) of the Rules of the United States Court of Federal Claims (“RCFC”) because he had received all the relief to which he was

2 entitled. Id. at 6–7. The Court determined that the government had sufficiently demonstrated that Plaintiff had already received two COVID-19 refunds of $1,800 and $1,400 in 2020 and 2021, respectively, and one $1,000 education credit in 2022, evidenced by Plaintiff’s account transcripts. Id. at 6–8. Because the IRS’s transcripts were verified by declaration and Plaintiff did not present reliable evidence of their untruthfulness, the Court presumed them correct. Id. at 6.

B. Plaintiff’s First Motion for Reconsideration

After the Court dismissed his case, Plaintiff filed a motion for reconsideration. ECF No. 34. First, Plaintiff alleges that his claim to the $1,000 education credit is no longer moot because he still had not received the refund from the IRS. Id. at 2–3. According to Plaintiff, the state correctional facility in which he is incarcerated returned the $1,000 check in question to the IRS upon the request of the IRS. Id. at 4. In support, Plaintiff provides records showing that “he never received $1,000 [for tax year] 2022 deposited into his trust account.” Id. at 4, 15–16. Furthermore, as to the two COVID-19 refunds, Plaintiff states that his 2020 and 2021 transcripts show a -$600 and -$1,200 balance due, and the IRS also owes him another $1,400. Id. at 8–9. Plaintiff argues that the transcripts provided by the government are not sufficient evidence that the IRS has paid him because they show payments that he had not received. Id. at 3, 5.

In its response to Plaintiff’s motion, the government stated that it did not object to granting Plaintiff’s motion as to the $1,000 education credit because Plaintiff’s most recent 2022 transcript shows that the credit was cancelled. ECF No. 35 at 1–2, 5; ECF No. 35-1 at 2–3. According to the government, this cancellation occurred on May 30, 2024, ECF No. 37 at 10, months after the government filed its February 2024 supplemental briefing, ECF No. 35 at 4. Conversely, the government did object to granting Plaintiff’s motion as to the COVID-19 refunds of $1,800 and $1,400 because the Court already “considered and rejected” those arguments. ECF No. 35 at 4. To remedy the IRS’s mistake regarding the education credit, the government requested that the Court reopen the case so that counsel could “recommend to an authorized delegate of the Attorney General that the United States issue a replacement check” to settle this matter. Id. at 5.

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