SHERWOOD v. UNITED STATES

Nos. 62-C-896, 63-C-805.

246 F.Supp. 502 (1965)

Ogden M. SHERWOOD, Plaintiff, v. UNITED STATES of America and Thomas E. Scanlon, District Director of Internal Revenue for the Eastern District of New York, Defendants. UNITED STATES of America, Plaintiff, v. John MULLER and Leonardo Casanova, Defendants.

United States District Court E. D. New York.

June 23, 1965.


Attorney(s) appearing for the Case

M. Francis Bravman, New York City, for plaintiff Ogden M. Sherwood; Charles L. Kades, Robert G. Desmond, Joseph A. McCue, New York City, of counsel.

Joseph P. Hoey, U. S. Atty., Eastern Dist. of New York, Brooklyn, N. Y., for United States and Thomas E. Scanlon, District Director of Internal Revenue for Eastern Dist. of New York; Barry Bloom, Asst. U. S. Atty., James N. McCune, Atty., Dept. of Justice, of counsel.

John F. Woog, Garden City, N. Y., for defendant John Muller.

Atwood C. Wolf, Jr., New York City, for defendant Leonardo Casanova.


BARTELS, District Judge.

This is a consolidation of two cases arising out of a joint and several 100% penalty assessment by the Government under Sections 6671 and 66721 of the Internal Revenue Code of 1954, 26 U.S. C.A., against John Muller (Muller), president, Ogden M. Sherwood (Sherwood), secretary and treasurer, and Leonardo Casanova (Casanova), a major stockholder and employee, of Gillmors...

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