“January 2014 data from the federal courts show that the number of tax lawsuits filed have declined nearly 10 percent in the past year, and are down over 30 percent from what they were five years ago. According to the case-by-case information analyzed by the Transactional Records Access Clearinghouse (TRAC), a total of 68 new tax lawsuits were filed in January 2014. The U.S. government was the plaintiff in nearly three-quarters (72%) of these suits. In the remaining 28 percent the government was named as a defendant. Various federal statutes are invoked as the cause of action in tax lawsuits. The most commonly used for the month of January 2014 were 26 USC 7401 – “IRS: Tax Liability” (37%), 26 USC 7402 – “IRS: Petition to Enforce IRS Summons” (25%) and  26 USC 7403 – “Suit to Enforce Federal Tax Lien” (9%). For the full report, including a five year timeline and top ten district rankings, go here.”