Weidmann v. U.S. Department of Treasury

DECISION AND ORDER

LARIMER, District Judge.

These are actions by Raymond C. Weid-mann (Weidmann), an accountant, for a refund of a “preparer’s penalty” assessed against him by the Internal Revenue Service (IRS) pursuant to § 6694(a) of the Internal Revenue Code (Code) for tax returns prepared during the years 1980-1982. There were nineteen separate returns, each of which resulted in penalties over the three-year period. The two actions, Civ. Nos. 84-958 and 84-1245, are hereby consolidated for trial to the court. The parties stipulated that since the pattern was the same, the court could…