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MATTINGLY v. U.S.

No. 86-2202C(1).

722 F.Supp. 568 (1989)

Donnell R. MATTINGLY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Missouri, E.D.

October 10, 1989.

Attorney(s) appearing for the Case

John Sullivan, St. Louis, Mo., for plaintiff.

Philip L. Sbarbaro, Office of Special Litigation, Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM

NANGLE, Chief Judge.

Donnell R. Mattingly, plaintiff, filed the instant action against the United States seeking the refund of payments made to the Internal Revenue Service ("IRS") in March of 1986. Plaintiff made said payments in partial satisfaction of assessments made against him for alleged violations of §§ 6700 and 6701 of the Internal Revenue Code. 26 U.S.C. §§ 6700 and 6701.

Specifically, the IRS assessed penalties...

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