United States of America, Cross-Appellant v. Allin M. Means, Cross-Appellee

These cases are cross-appeals from a judgment, entered February 22,1978, of the United States District Court for the Western District of Tennessee. In that judgment the court sustained the imposition by the Commissioner of a 26 U.S.C. § 6672 penalty against taxpayer Allin M. Means, but disallowed interest accruing on that penalty during the pendency of the trial proceedings. The decision of the district court is unreported.

In 1971, the Government was interpleaded as a defendant in a proceeding entitled Hyde Properties v. Clyde McCoy, et al., C.A. No. C-71-408 (W.D.Tenn.), contesting the…