Googe v. Secretary of the Treasury

MEMORANDUM

ROBERT L. TAYLOR, Chief Judge.

This is an action challenging an administrative penalty of $500.00 imposed on plaintiff by the Internal Revenue Service for filing a tax return deemed “frivolous” pursuant to 26 U.S.C. § 6702. Jurisdiction of this cause is conferred upon this Court by virtue of 28 U.S.C. § 1346 and 26 U.S.C. §§ 6703 and 7422. This case is before the Court on defendant’s motion to dismiss or for summary judgment. Argument on this motion was heard in open court on December 29, 1983.

The summary of the facts set forth in defendant’s brief in support of its motion is…