Allison v. United States

OPINION AND ORDER

WOLSKI, Judge.

These three cases concern negligence penalties imposed on taxpayers under the former section 6653 of the Internal Revenue Code. The plaintiffs in each case seek refunds of these penalties, paid because deductions and credits they claimed on their taxes stemmed from investments in what was ultimately determined to be an abusive tax shelter. The Court consolidated these cases for purposes of conducting a trial, which was held over *569two days in Atlanta, Georgia.1 After conclusion of the trial, the plaintiffs (jointly) and the government submitted thorough post-trial…