cause of action only where a defendant willfully files. information returns that misrepresent the amount of payments made. For the foregoing reasons, plaintiffs tax fraud allegations in the Amended Complaint fail to state a claim for relief under § 7434(a), and Count II must therefore be dismissed. An appropriate Order will issue. 1 . 29 U.S.C. § 201 etseq. , 2 . These allegations are derived from the Amended Complaint. See Columbia Venture, LLC v. Dewberry & Davis, LLC, 604 F.3 Cir.2015) (affirming judgment for plaintiffs where defendant falsely. claimed to have made payments); Vandenheede v. Vecchio, 541 Fed.Appx. 577, 579-82 (6th Cir. 2013) (affirming dismissal for failure to plead fraud with particularity); Katzman v. Essex Waterfront Owners LLC, 660 F.3d 565, 568 (2d Cir.2011) (<HOLDING>); Cavoto v. Hayes, 634 F.3d 921, 924 (7th
holding failure to file statement of points is no bar to appeal holding blank return did not provide sufficient information despite taxpayers income being below the filing threshold holding that information furnished to preparer of tax return is not privileged holding that intentional failure to file an information return is not a willful filing holding reasonable an agency determination that a request for an investigative file did not include the employment file