D. Robert Autrey, Jr., an Individual, Cross-Appellants v. United States of America, Cross-Appellee

KRAVITCH, Circuit Judge:

Appellees-cross-appellants brought suit challenging penalties the Internal Revenue Service had assessed under Internal Revenue Code sections 6700, 6701, and 6694 for promoting abusive tax shelters and aiding and abetting understatement of tax liability.1 A jury found in favor of appellees and the government appeals, citing as error certain of the district court’s jury instructions. Appellees cross-appeal from a decision of the district court that the court lacked jurisdiction to entertain the claim of appellee D. Robert Autrey, Jr. for a refund, as well as the court’s…