Tax Coda

Tax Coda

Court dismisses Schiff lawsuit alleging IRS tax enforcement conspiracy

Peter David Schiff v. IRS. United States District Court for the District of Puerto Rico. No. 3:24-cv-01511.

Tax Coda's avatar
Tax Coda
Mar 14, 2026
∙ Paid

A federal Court dismissed Peter Schiff’s lawsuit against the IRS and its investigators because the complaint relied on speculation and failed to allege specific facts showing unlawful government conduct.

Holding

The U.S. District Court for the District of Puerto Rico dismissed all claims brought by Peter Schiff against the United States and individual IRS officials.

Claims against the United States were barred by sovereign immunity and failure to exhaust administrative remedies under the Federal Tort Claims Act.

Remaining constitutional claims against individual IRS agents were dismissed because the complaint failed to allege unlawful conduct plausibly.

Why It Matters

  • Conspiracy allegations require facts. Courts will dismiss claims against the IRS when complaints rely on speculation rather than specific factual allegations.

  • Sovereign immunity remains a major barrier. Lawsuits against the IRS or federal officials acting in their official capacity are treated as suits against the United States…

User's avatar

Continue reading this post for free, courtesy of Tax Coda.

Or purchase a paid subscription.
© 2026 Tax Coda · Publisher Terms
Substack · Privacy ∙ Terms ∙ Collection notice
Start your SubstackGet the app
Substack is the home for great culture