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COHN v. UNITED STATES

No. 71 C 982.

399 F.Supp. 168 (1975)

Arnold M. COHN et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E. D. New York.

July 28, 1975.

Attorney(s) appearing for the Case

Lippe, Ruskin & Schlissel, P. C., Mineola, N. Y., for plaintiffs.

David Trager, U. S. Atty., E. D. N. Y. by Henry Brachtl, Asst. U. S. Atty., Brooklyn, N. Y., Thomas Lawler, Trial Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM AND ORDER

BRAMWELL, District Judge.

This is a motion by the defendant, UNITED STATES OF AMERICA, for partial summary judgment pursuant to Rule 56(b) of the Federal Rules of Civil Procedure.

In March, 1970, the District Director of Internal Revenue for the Eastern District of New York made two penalty assessments against plaintiffs, in the amount of $33,805.49. The assessments were made pursuant to 26 U.S.C. § 6672

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