Wesley v. United States

ORDER

VINSON, District Judge.

Pending is the defendant’s motion for summary judgment. (Doc. 32).

Plaintiffs, Woodburn Wesley, Jr. (“Wesley”), and Sharon Wesley, brought an action in this court seeking a refund of tax penalties assessed against them under Title 26, ’ United States Code, Sections 6651(a)(1) & 6654(a). The defendant now moves for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure. Unless otherwise noted, the following facts appear to be undisputed.

I. FACTUAL BACKGROUND

Wesley is an attorney licensed to practice in Florida. He holds advanced degrees in…