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SPRIGGS v. U.S.

Civ. A. No. 86-0703-R.

660 F.Supp. 789 (1987)

William SPRIGGS, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Virginia, Richmond Division.

May 15, 1987.

Attorney(s) appearing for the Case

John B. Boatwright, III, Richmond, Va., Michael Savage, Gersten, Savage, Kaplowitz & Zukerman, New York City, for plaintiff.

Robert W. Jaspen, Asst. U.S. Atty., U.S. Atty.'s Office, Richmond, Va., Wilbur T. Miller, Office of Sp. Litigation, Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

OPINION

RICHARD L. WILLIAMS, District Judge.

This matter comes before the Court on the parties' cross-motions for summary judgment. The case presents the legal issue of the proper method for calculating penalties under § 6700 of the Internal Revenue Code, 26 U.S.C. § 6700 (1982), amended by 26 U.S.C. § 6700 (Supp. III 1985). Specifically, does § 6700 provide for a penalty of $1,000 per sale of an interest in an abusive tax...

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