for public use, without just compensation." U.S. Const, amend. V. 16 . Plaintiffs’ April 3, 2009 Complaint alleges that Plaintiffs never received a Notice of Deficiency for any of the tax years at issue. Compl. at 2. Plaintiffs, however, attached a copy of a Notice of Deficiency for 1997 and 1998 in their Petition to the Tax Court challenging the deficiency determinations for these years. Gov't Mot. Ex. C. Further, Plaintiffs did not dispute their receipt of a Notice of Deficiency at the November 15, 2002 CDP hearing. Gov’t Mot. Exs. E, G, H. Section 2514 of Title 28 of the United States Code requires forfeiture of a tax claim when a party attempts to establish its claim through fraud. 28 U.S.C. § 2514; see also Standard Oil v. United States, 98 Ct.Cl. 201, 246, 47 F.Supp. 120 (1942) (<HOLDING>); see also Kamen Soap Products v. United
holding that plaintiffs claim for refund of corporate income taxes was forfeited when plaintiff presented forged corporate minutes to the irs with the knowledge they were forged holding that a fraudulent transfer claim against a corporate debtors control person belongs to the corporate debtor not to specific creditors holding that a corporate officer signing a contract in his corporate capacity is generally not liable for damages under the contract holding that the general corporate laws are incorporated into the corporate charter holding that grand jury testimony of officer and inhouse counsel for corporate defendant was properly admitted as admission against the corporate defendant