Emanuel v. United States

MEMORANDUM OPINION AND ORDER

MAROVICH, District Judge.

Plaintiff Bertram Emanuel (“Emanuel”) brought suit against the United States of America to contest penalty assessments made against him by the Internal Revenue Service pursuant to 26 U.S.C. Section 6700 for allegedly promoting an abusive tax shelter, and pursuant to 26 U.S.C. Section 6701 for aiding and abetting in the understatement of the tax liability of another individual. Plaintiff has moved for summary judgment on the ground that the government’s assessments are time barred. Plaintiff has moved, in the alternative, for partial summary…