V-1 Oil Co. v. United States

MEMORANDUM DECISION AND ORDER AND ORDER OF REASSIGNMENT

LODGE, Chief Judge.

The plaintiffs have moved for partial summary judgment (Dkt. No. 12) on the issues of the defendant’s assessment of penalties under 26 U.S.C. §§ 6653(a) and 6661. The plaintiffs assert that the penalty issues can be decided separately from the questions concerning the propriety of the deductions and request that the court rule as a matter of law that it is not liable for any penalty amounts. For the reasons explained below, the motion is granted to the extent such relief is consistent with the parties’ stipulation,…