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PENNER v. UNITED STATES

No. 83-8583-Civ-JCP.

582 F.Supp. 432 (1984)

Luz PENNER, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, S.D. Florida.

January 25, 1984.

Attorney(s) appearing for the Case

Edward R. Shohat, Bierman, Sonnett, Beiley, Shohat & Sale, P.A., Edward P. Guttenmacher, Richman & Guttenmacher, P.A., Miami, Fla., for plaintiff Luz Penner.

Stanley Marcus, U.S. Atty., S.D. Fla., Miami, Fla. by Randall M. Roden, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant U.S.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

PAINE, District Judge.

This cause came on for trial upon the complaint of Plaintiff, seeking review of an assessment of Federal personal income taxes, entered against Plaintiff by Defendant's Internal Revenue Service (hereinafter "IRS") in August, 1983, pursuant to Section 6861 of the Internal Revenue Code of 1954, as amended (26 U.S.C. § 6861). Section 7429(b)(1) of the Internal Revenue Code (26 U.S.C. §...

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