United States v. William J. Alt, M.D. Rosalinda Alt Karen Alt Robert W. Alt, William J. Alt, M.D.

Dr. William At appeals a civil verdict for the plaintiff United States in an action to collect back taxes, interest, and statutory penalties under the Internal Revenue Code. At, who had already pled guilty to criminal charges of income tax fraud, contends that the award of statutory penalties to the government violates the Double Jeopardy and Excessive Fines Clauses of the Constitution. The district court rejected At’s defense, holding that the award of tax penalties was not “punishment” under United States v. Halper, 490 U.S. 435, 447-48, 109 S.Ct. 1892, 1901, 104 L.Ed.2d 487 (1989). We…