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LAWRENCE v. UNITED STATES

Civ. A. No. 3-1955-C.

299 F.Supp. 187 (1969)

Carmen L. LAWRENCE, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court N. D. Texas, Dallas Division.

April 21, 1969.

Attorney(s) appearing for the Case

Locke, Purnell, Boren, Laney & Neely, by J. J. French, Jr., Dallas, Tex., Palmer, Green, Palmer & Burke, by Philip I. Palmer, Sr., Dallas, Tex., for plaintiff.

John O. Jones, Atty., Dept. of Justice, Tax Division, Fort Worth, Tex., Eldon B. Mahon, U. S. Atty., Martha Joe Stroud, Asst. U. S. Atty., Dallas, Tex., for defendant.

OPINION

WILLIAM M. TAYLOR, Jr., District Judge.

Petitioner here sues for recovery of a 100% penalty assessment made on February 5, 1965 against her individually and as independent executrix of her husband's estate. The Internal Revenue Service levied the assessment pursuant to 26 U.S.C.A. 66721 for unpaid excise, withholding and F.I.C.A. taxes of Casa View Country Club, Inc. for the fourth quarter of 1960 and the first, second...

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