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UNITED STATES v. MEANS

Nos. 78-1262, 78-1263.

621 F.2d 236 (1980)

UNITED STATES of America, Plaintiff-Appellee, Cross-Appellant, v. Allin M. MEANS, Defendant-Appellant, Cross-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 9, 1980.

Attorney(s) appearing for the Case

William H. Luck, Joseph G. Wilson, Jr., Memphis, Tenn., for defendant-appellant, cross-appellee.

W. J. Michael Cody, U.S. Atty., Memphis, Tenn., Gayle P. Miller, M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Richard Farber, Thomas M. Walsh, Grant W. Wiprud, Tax Div., U.S. Dept. of Justice, Washington, D.C., for plaintiff-appellee, cross-appellant.

Before EDWARDS, Chief Judge, BOYCE F. MARTIN, Jr., Circuit Judge, and PHILLIPS, Senior Circuit Judge.

PER CURIAM.

These cases are cross-appeals from a judgment, entered February 22, 1978, of the United States District Court for the Western District of Tennessee. In that judgment the court sustained the imposition by the Commissioner of a 26 U.S.C. § 6672 penalty against taxpayer Allin M. Means, but disallowed interest accruing on that penalty during the pendency of the trial proceedings. The decision of the district court is unreported.

In 1971, the Government...

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