Gerald B. Lefcourt, P.C. v. United States

WALKER, Circuit Judge:

Plaintiff-appellant Gerald B. Lefcourt, P.C. (“Lefcourt” or “the law firm”) appeals from the May 16, 1996 judgment entered in the United States District Court for the Southern District of New York (Robert P. Patterson, Jr., District Judge), granting the United States’ motion for summary judgment and denying plaintiffs cross-motion for summary judgment in plaintiffs tax refund action. In so doing, the district court affirmed the imposition of a $25,000 penalty by the Internal Revenue Service (“IRS”) on the ground that Lefcourt had intentionally failed to comply with…