Hill v. United States

OPINION

MILES, Senior District Judge.

This is an action for a refund of money paid to the Internal Revenue Service (IRS) as a civil penalty assessed pursuant to 26 U.S.C. § 6700. That section provides for the imposition of a penalty on those who promote “abusive tax shelters.” The $32,-000 penalty assessed against plaintiff resulted from his alleged involvement with a tax shelter known as O.E.C. Leasing Corporation (OEC). This matter is presently before the Court on both plaintiff and defendant’s motions for partial summary judgment. The issue presented is whether the IRS correctly computed the…