Cook v. United States

MEMORANDUM

CALDWELL, District Judge.

I. Introduction

This action arises pursuant to Section 6672 of the Internal Revenue Code (26 U.S.C. § 6672), which imposes penalties for failure of responsible persons to collect and pay over taxes to the United States. Plaintiff, Dean A. Cook, filed a complaint against the United States of America, to recover an amount paid in partial satisfaction of a § 6672 assessment against him, which he alleges was improperly adminis tered. The Government responded with a counterclaim against Cook to enforce judgment and collect the balance of the assessment.…