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HOUSTON v. U.S.

Nos. G86-937 CA5, G86-938 CA5.

682 F.Supp. 340 (1988)

Michael HOUSTON, Plaintiff, v. UNITED STATES of America, Defendant. PLANNED INVESTMENTS, INC. a Michigan Corporation, Plaintiff, v. UNITED STATES of America, Defendant.

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

March 28, 1988.

Attorney(s) appearing for the Case

Thomas A. Klug, Okemos, Mich., for plaintiffs.

S. Hollis Fleischer, Dept. of Justice, Tax Div., Washington, D.C., for defendant.

OPINION OF THE COURT

BELL, District Judge.

In these two consolidated actions under 28 U.S.C. § 1346(a)(1), plaintiffs Michael Houston and the company of which he was President, Planned Investments, Inc., contest a penalty assessed by the Internal Revenue Service. Now before the Court are the parties' cross-motions for summary judgment pertaining only to Planned Investments, Inc. v. United States, G86-938 CA5.

The subject penalty was assessed...

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