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FIELD v. U.S.

No. 01 CIV.3000(SAS).

307 F.Supp.2d 498 (2003)

David A. FIELD and Ellen J. Field, Plaintiffs, v. UNITED STATES of America, Defendant.

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

November 18, 2003.

Attorney(s) appearing for the Case

Elliot I. Miller, Esq., Kleban & Samor, P.C., Southport, CT, for Plaintiffs.

Edward Chang, Assistant United States Attorney, United States Attorney's Office, Southern District of New York, New York, for the Government.

CORRECTED OPINION AND ORDER

SCHEINDLIN, District Judge.

David and Ellen Field (the "Fields") seek a refund of tax-motivated transaction interest in the amount of $87,382, assessed and collected by the Internal Revenue Service ("IRS"), in December, 1999, under former section 6621(c)1 of the Internal Revenue Code, Title 26 of the United State Code. The Fields now move for summary judgment, arguing that the assessment and...

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