In the adjudicated case of Peter David Schiff v. IRS, Mr. Schiff presented a theory.
The IRS investigated him. Euro Pacific International Bank, a financial institution he owned, collapsed. A $17.5 million stock sale to Qenta fell through. Puerto Rico regulators, who initially supported the sale, had a change of heart. And a reporter received information that could only have come from an official source. The sequence appeared coordinated, so he concluded there was coordination.
Then he sued.
The Court dismissed the case, stating that a sequence of events does not constitute a legal claim.
This point deserves emphasis. The complaint alleged that IRS investigators pressured Puerto Rico regulators, leaked damaging information, and coordinated efforts to bring down the bank. The Court did not find evidence that these actions occurred. Instead, it determined that the complaint failed to connect these events to specific unlawful acts by named officials within a legal framework that would permit …
