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U.S. v. PHILA. YEARLY MEETING OF RELIGIOUS SOC.

Civ. A. Nos. 88-6368, 88-6390.

753 F.Supp. 1300 (1990)

UNITED STATES of America v. PHILADELPHIA YEARLY MEETING OF the RELIGIOUS SOCIETY OF FRIENDS. (Two Cases)

United States District Court, E.D. Pennsylvania.

December 20, 1990.

Attorney(s) appearing for the Case

Valentina G. Viletto, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., David M. Katinsky, for plaintiff.

Peter Goldberger, Philadelphia, Pa., for defendant.

MEMORANDUM AND ORDER

SHAPIRO, District Judge.

The United States brought these civil actions in August, 1988, to enforce two Internal Revenue Service levies, authorized by 26 U.S.C. 6332(c)(1), upon the Philadelphia Yearly Meeting of the Religious Society of Friends ("Yearly Meeting"). In each case, the government seeks to impose a 50% penalty, authorized by 26 U.S.C. 6332(c)(2), on the ground that the Yearly Meeting refused to honor the levies without reasonable...

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