United States v. Quality Medical Consultants, Inc.

ORDER

CONWAY, District Judge.

This cause comes before the Court on appeal from the decision of the United States Bankruptcy Court for the Middle District of Florida, Orlando Division (“Bankruptcy Court”), partially sustaining Quality Medical Consultants, Inc.’s (“Appellee”), objection to a $245,314 claim filed by the Internal Revenue Service (“IRS”). This claim was based on a penalty assessed by the IRS pursuant to 26 U.S.C. §§ 6721(e) and 6722(c), for intentional disregard of tax filing requirements for tax years 1993 and 1994. The Bankruptcy Court reduced the $245,315 penalty to $1,350,…