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DUDLEY v. UNITED STATES

No. 43198.

285 F.Supp. 979 (1967)

Robert G. DUDLEY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court N. D. California.

November 7, 1967.

Attorney(s) appearing for the Case

Heisler & Stewart, Carmel, Cal., with Francis Hesiler, Carmel, Cal., for plaintiff.

Cecil F. Poole, U. S. Atty., San Francisco, Cal., with Barbara Ashley Phillips, San Francisco, Cal., for defendant United States.

MEMORANDUM OPINION

WOLLENBERG, District Judge.

Plaintiff has brought this action to recover funds in the amount of $3,734.24 assessed against and collected from him by the Internal Revenue Service as penalties under Title 26 U.S.C. Section 6672. The United States has counterclaimed for $9,258.37, representing the difference between the total amount assessed and the amount collected from plaintiff.

The assessment against plaintiff arose out of the...

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