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DECKER v. UNITED STATES

No. 142-75.

531 F.2d 543 (1976)

George E. DECKER and Effie J. Decker v. The UNITED STATES.

United States Court of Claims.

March 17, 1976.

Attorney(s) appearing for the Case

Paul P. Lipton, Milwaukee, Wis., atty. of record, for plaintiffs. Richard A. Petrie, Milwaukee, Wis., of counsel.

James L. Malone III, Washington, D.C., with whom was Asst. Atty. Gen. Scott P. Crampton, Washington, D.C., for defendant. Theodore D. Peyser, Jr. and Robert S. Watkins, Washington, D.C., of counsel.

Before COWEN, Chief Judge, KUNZIG and BENNETT, Judges.

ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

PER CURIAM:

This case requires us to determine the point at which interest begins to accrue on civil fraud penalties assessed pursuant to the jeopardy assessment provisions of the Internal Revenue Code. The relevant facts are not in dispute. On May 19, 1972, the Internal Revenue Service (IRS), pursuant to Section 6861(a) of the Internal Revenue Code of 1954,1 made jeopardy assessments...

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