The opinion of the court was delivered by: Valerie B. Fairbank United States District Judge
Order of Permanent Injunction Against Susan Guan
Plaintiff United States of America and defendant Susan Guan ("defendant"), stipulate as follows:
Defendant waives the entry of findings of fact and conclusions of law under Rules 52 and 65 of the Federal Rules of Civil Procedure.
Defendant understands that this Stipulated Judgment of Permanent Injunction constitutes the final judgment in this matter, and waives any and all right to file an appeal from this judgment.
Defendant consents to the entry of this Stipulated Judgment of Permanent Injunction without further notice and agrees to be bound by its terms. Defendant further understands and agrees that the Court will retain jurisdiction over this matter for the purpose of implementing and enforcing this injunction, and understands that if she violates this injunction, she may be found to be in contempt of court and may be sanctioned or imprisoned. The parties agree that entry of this permanent injunction neither precludes the Internal Revenue Service from assessing penalties against defendant for asserted violations of the Internal Revenue Code ("IRC"), nor precludes defendant from contesting any such penalties.
IT IS HEREBY ORDERED pursuant to 26 U.S.C. §§ 7402, 7407, and 7408 that defendant Susan Guan and her representatives, agents, servants, employees, attorneys, independent contractors, anyone in active concert or participation with him, are PERMANENTLY ENJOINED from directly or indirectly;
(1) Preparing or filing, or assisting in, or directing the preparation or filing of any federal income tax return, amended return, IRS Form 1099, 1099-OID, 1096, Schedule B, or any other tax-related documents or forms for any other person or entity;
(2) Engaging in any other activity subject to penalty under the Internal Revenue Code;
(3) Engaging in other conduct that substantially interferes with the proper administration and enforcement of the internal revenue laws;
(4) Organizing or selling tax shelters, plans or arrangements that advise or assist taxpayers to attempt to evade the assessment or collection of such taxpayers' correct federal tax;
(5) Engaging in any other activity subject to penalty under 26 U.S.C. § 6700, including organizing or selling a plan or arrangement and making a statement regarding the excludability of income or securing of any other tax benefit by participating in the plan that defendant knows or has reason to know is false or fraudulent as to any material matter;
(6) Engaging in any other activity subject to penalty under 26 U.S.C. § 6701;
(7) Directly or indirectly organizing, promoting, marketing, or selling any plan or arrangement that advises or encourages taxpayers to attempt to violate internal revenue laws or unlawfully evade the assessment or collection of their federal tax liabilities, including promoting, selling, or advocating the use of the ...