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EVANS v. INTERNAL REVENUE SERVICE

No. 80-40269.

539 F.Supp. 805 (1982)

Edmund S. EVANS, Plaintiff, v. INTERNAL REVENUE SERVICE, et al., Defendants.

United States District Court, E. D. Michigan, S. D.

January 26, 1982.

Attorney(s) appearing for the Case

Edmund S. Evans, pro. per.

Robert W. Haviland, Asst. U. S. Atty., Flint, Mich., John A. DiCicco, Tax Div., Dept. of Justice, Washington, D. C., for defendants.

MEMORANDUM OPINION AND ORDER

NEWBLATT, District Judge.

Plaintiff has filed this action challenging the legality of Internal Revenue Code § 6694(a) under the Fifth, Seventh, Eighth and Fourteenth Amendments to the United States Constitution. Defendant has filed a motion to dismiss; plaintiff has replied, and it is this motion which is presently before the Court.

Section 6694(a) of the Internal Revenue Code, 26 U.S.C. reads as follows:

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