Schuloff v. Queens College Foundation, Inc.
Plaintiff Anita Schuloff filed two separate lawsuits against Queens College Foundation, Inc. and Brooklyn College Foundation, Inc., which were consolidated due to identical legal issues. Schuloff alleged violations of 26 U.S.C. § 6104 for the defendants' failure to promptly provide federal tax returns for public inspection, along with claims under 42 U.S.C. § 1983 and New York Freedom of Information Law. The defendants moved to dismiss the complaints under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). The Court granted the motions to dismiss under Rule 12(b)(6), ruling that 26 U.S.C. § 6104 does not create a private cause of action, thus precluding the related § 1983 claims. Consequently, the Court declined supplemental jurisdiction over the state law claims, dismissing both complaints in their entirety.