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UNITED STATES v. DAVIDSON

No. G80-862.

558 F.Supp. 1048 (1983)

UNITED STATES of America, Plaintiff, v. Richard A. DAVIDSON and Merle R. Jenkins, Defendants, and Richard A. DAVIDSON, Counter-Plaintiff, v. UNITED STATES of America, Counter-Defendant.

United States District Court, W.D. Michigan, S.D.

February 15, 1983.

Attorney(s) appearing for the Case

Allen R. Mass, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., Robert C. Greene, Asst. U.S. Atty., Grand Rapids, Mich., for plaintiff.

Chris Parfitt, Jenkins, Nystrom & Strelacci, P.C., Southfield, Mich., for defendant.

OPINION

ENSLEN, District Judge.

On March 20, 1978, a delegate of the Secretary of the Treasury made an assessment, pursuant to Section 6672 of the Internal Revenue Code of 1954, 26 U.S.C. § 6672, and gave notice of the assessment and demand for payment against Defendant Richard A. Davidson. The assessment, in the amount of $87,535.99, was based on a determination by the United States that Davidson was a...

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