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MILLER v. U.S.

No. C-90-3132 MHP.

813 F.Supp. 715 (1992)

Albert J. MILLER, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. California.

September 15, 1992.

Attorney(s) appearing for the Case

Jon B. Sigerman, Theodore A. Kolb, Sullivan Roche & Johnson, San Francisco, CA, for plaintiff.

William T. McGivern, Jr., U.S. Atty., Jay R. Weill, U.S. Atty's Office, Tax Div., San Francisco, CA, for defendants.

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER

PATEL, District Judge.

This matter arises out of an international withholding tax audit conducted by the Internal Revenue Service ("IRS") under 26 U.S.C. § 1441 against Albert Miller as withholding agent for A-Alphatronics, Inc.. The IRS recommended withholding tax liability in excess of $10,000,000 and additional penalties in excess of $6,000,000.

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