Bailey v. United States

ORDER

BILBY, District Judge.

The Plaintiff, a tax preparer, filed suit seeking return of civil penalties assessed against him by the Internal Revenue Service (IRS). Both parties now move for summary judgment. The Court finds that the Defendant is entitled to judgment as a matter of law, and herein grants the Defendant’s motion and denies the Plaintiffs motion.

BACKGROUND

The Plaintiff is a Certified Pubic Accountant who prepared the tax returns for then husband and wife James and Susan Pierce in 1991 and 1992. He also performed certain accounting services for Duke’s Video Movies Etc., a…