International Automated Systems (fka IAUS)

[scion]

Count IV: Injunction Under § 7402(a) Against Shepard

139. The United States incorporates by reference the allegations contained in paragraphs 1through 118.

140. Shepard, through his actions described above, including making false or fraudulent statements regarding the law and facts applicable to material matters under the internal revenue laws, facilitating customers’ claims for tax benefits to which they were not entitled, encouraging customers to “sponsor” others into the solar energy scheme, collecting “commissions” and/or other income from the abusive solar energy scheme, and interfering with the IRS’s process of examining customers’ tax returns, has substantially interfered, and continues to substantially interfere, with the enforcement of the internal revenue laws.

141. Unless enjoined, Shepard has shown that he is in a position to, and likely will, continue to engage in such unlawful conduct and to interfere with the enforcement of the internal revenue laws.

142. The United States will suffer irreparable injury if Shepard is not enjoined.

143. Enjoining Shepard is in the public interest because an injunction, backed by the Court’s contempt powers if needed, will stop Shepard’s illegal conduct and the harm it causes the United States.

144. The requested injunction against Shepard is necessary or appropriate to stop his unlawful conduct and this Court should impose such injunctive relief under § 7402(a).


Extract -
Doc 2 PDF file
https://www.scribd.com/doc/291081416/USA-v-RaPower-3-Et-Al-Doc-2-Filed-23-Nov-15