Levy v. United States

DAWKINS, JR., Chief Judge.

This action having been heard at a trial on the merits, before the Court without a jury, the Court having considered the pleadings, the stipulation of counsel, the evidence, the arguments and briefs of counsel, makes the following

Findings of Fact

1

This is a suit to recover from the Government the amount of a penalty assessed against, and paid by, plaintiff, by the District Director of Internal Revenue under purported authority of Section 2707 (a) of the Internal Revenue Code of 1939, 26 U.S.C. § 2707.

2

Plaintiff is a resident citizen of Shreveport, Louisiana. During…