Planned Investments, Inc., Michigan Corporation v. United States

MERRITT, Circuit Judge.

The issue in this tax case is the adequacy of the notice sent by the Internal Revenue Service (“IRS” or “Government”) to inform plaintiff, Planned Investments, Inc. (“PI”) that it had been assessed a penalty of $64,000 under § 6700 of the Internal Revenue Code (“Code”), 26 U.S.C. § 6700, for Pi’s promotion of an abusive tax shelter. The District Court, finding that the notice was inadequate and unfair because it did not clearly specify the time period involved, granted summary judgment to plaintiff and abated the penalty. The Government appeals the grant of summary…