United States v. Cooksey

*234MEMORANDUM OPINION AND ORDER

SANDERS, Chief Judge.

On September 21, 1992, the Court held a non-jury trial in this case. The government seeks judgment against Cooksey for two 100% penalty assessments made against him, one for $103,773.85, dated July 11, 1983, and another for $16,590.00, dated May 21, 1984.

I. Stipulations

In the First Revised Joint Pretrial Order, filed September 17, 1992, the parties stipulated to the following facts:

1) Plaintiff is the United States of America.

2) Defendant is a citizen of the United States and resides in Dallas County, Texas.

3) All parties are properly before…