Kuchan v. United States

MEMORANDUM OPINION

KOCORAS, District Judge:

This dispute concerns the interpretation and application of § 6701 of the Internal Revenue Code of 1954, as amended (the “Code”). 26 U.S.C.A. It is presently before the court on defendant’s motion for partial summary judgment and plaintiffs motion for summary judgment. For the reasons contained herein, defendant’s motion is granted and plaintiff’s motion is denied.

FACTS

Plaintiff, William T. Kuchan, is a certified public accountant who provides tax and financial advice and reviews and prepares tax returns for his clients. He has been an accountant…