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KADAH v. UNITED STATES

No. 81-CV-1253.

600 F.Supp. 1302 (1985)

Hassan KADAH, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. New York.

January 2, 1985.

Attorney(s) appearing for the Case

Costello, Cooney & Fearon, Syracuse, for plaintiff; Warren W. Bader, Syracuse, N.Y., of counsel.

Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant; D. Patrick Mullarkey, Chief, Civ. Trial Section, Northern Region, Steven Lyons, Jonathan B. Forman, Washington, D.C., of counsel.

MEMORANDUM-DECISION and ORDER

MINER, District Judge.

I

Invoking the jurisdiction conferred upon this Court by the provisions of 28 U.S.C. § 1346(a)(1) and § 7422 of the Internal Revenue Code of 1954 ("I.R.C."), plaintiff Hassan Kadah ("Kadah") seeks to recover the 100% penalty assessment he has paid pursuant to I.R.C. § 6672 in discharge of the unsatisfied withholding and Federal Insurance Contributions Act ("FICA") tax liabilities...

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