UNITED STATES v. BERKOWITZ

Civ. A. No. 31442.

214 F.Supp. 579 (1962)

UNITED STATES of America v. Morton BERKOWITZ.

United States District Court E. D. Pennsylvania.

November 28, 1962.


Attorney(s) appearing for the Case

Drew J. T. O'Keefe, Graeme Murdoch, Asst. U. S. Atty., Philadelphia, Pa., for plaintiff.

Raymond L. Shapiro for Wexler, Mulder & Weisman, Philadelphia, Pa., I. Arnold Ross, New York City, of counsel, for defendant.


JOSEPH S. LORD, III, District Judge.

This is a suit to recover a penalty in the amount of $63,653.75, the assessment having been made on May 31, 1956, against the defendant by the District Director of Internal Revenue of Philadelphia, Pennsylvania. The complaint was filed on May 14, 1962, 17 days short of the statute of limitations. See 26 U.S.C. § 6502(a) (1).

At the time the assessment was made the defendant was living in Philadelphia and service of...

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