Mok Partners v. United States

MEMORANDUM OPINION AND ORDER

ASPEN, District Judge:

Plaintiffs MOK Partners, Frank Malart-sik, Paul Obholtz, and Kenneth Kowalski brought this action against the United States to challenge a $24,400.00 penalty assessed by the Internal Revenue Service. Plaintiffs moved for partial summary judgment. The United States moved for summary judgment. For the following reasons, we grant the United States’ motion and deny plaintiffs’ motion.

I

The following facts are undisputed. 1 In 1983, MOK Partners convinced five individuals, a two-person partnership, and an investment partnership (Greenwood Investment…