ORDER
This document is a federal court order granting the United States government's motion for summary judgment against tax preparer Tanja D. Hollis. The order permanently enjoins Hollis from preparing tax returns and requires her to pay $567,000 in disgorgement of fees earned from allegedly fraudulent filings.
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About this document
A plain-language guide to the contents and context of this specific DOJ filing.
Court's basis for granting summary judgment
The order states that the court granted summary judgment because Hollis did not respond to the government's motion, and the undisputed facts showed no genuine dispute requiring trial. The court applied the legal standard that summary judgment is appropriate when there is no material factual dispute and the moving party is entitled to judgment as a matter of law. The order notes that while a court cannot grant summary judgment solely because a motion is unopposed, it must determine if the undisputed facts warrant judgment.
Supported by PDF pages 1, 2Allegations against the tax preparer
According to the order, the government alleged Hollis prepared thousands of tax returns containing false information between 2014-2025, including fabricated business income/losses and education credits. The order states IRS examinations found over 90% of sampled returns required adjustments, allegedly resulting in $1.5 million in tax deficiencies. The government claimed Hollis continued this conduct after receiving prior penalties in 2016 and 2018. The order cites customer statements that Hollis allegedly included false information without their knowledge to increase refunds.
Supported by PDF pages 3, 4, 5Legal authority for injunction
The order explains three legal bases for the injunction under the Internal Revenue Code. Section 7407 allows injunctions against tax preparers who violate penalty provisions like knowingly understating liabilities. Section 7408 permits injunctions for conduct subject to penalty for aiding tax understatements. Section 7402(a) provides general authority to issue injunctions to enforce tax laws. The order states each statute provides independent grounds for relief and describes the specific prohibited conduct under each.
Supported by PDF pages 6, 7, 13, 14Scope of the permanent injunction
The order permanently prohibits Hollis from preparing or filing federal tax returns for others, assisting in preparing returns that understate tax liabilities, engaging in activities subject to specified tax penalties, and interfering with tax administration. The injunction applies to Hollis and anyone acting with her. The order states these restrictions are based on findings that narrower measures would be insufficient given the alleged pattern of conduct.
Supported by PDF page 17Disgorgement calculation
The order requires Hollis to pay $567,000, which it describes as a reasonable approximation of fees from allegedly fraudulent returns. The calculation assumes a 90% error rate across 3,604 returns filed from 2022-2025, multiplied by the lowest reported fee of $175 per return. The order states this estimate is based on IRS examination samples showing high error rates and that Hollis did not contest the calculation.
Supported by PDF pages 16, 17Procedural posture and limitations
The order notes it resolves the government's motion for summary judgment but does not address all claims in the complaint, stating the court treats unaddressed claims as abandoned. It emphasizes the findings are based on undisputed facts due to Hollis not responding to the motion. The order states it makes no determinations about other potential legal issues not raised in the motion.
Supported by PDF pages 17, 18Document record
- Document type
- Court order
- Category
- Civil
- Publication date
- 2026-11-10
- DOJ office
- Office of Public Affairs
- Case number
- 3:25-cv-00143-LMM
- Collected
- 2026-11-13
- Original filename
- 00021_order_-_granting_msj_permanent_injunction_w_disgorgement_hollis_25-cv-143ndga26070782.1.pdf
Source & integrity
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