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BROCKHOUSE v. UNITED STATES

No. 83-2689.

749 F.2d 1248 (1984)

John BROCKHOUSE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided December 13, 1984.

Attorney(s) appearing for the Case

Kimball R. Anderson, Winston & Strawn, Chicago, Ill., for plaintiff-appellant.

Patricia A. Willing, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before COFFEY and FLAUM, Circuit Judges, and CAMPBELL, Senior District Judge.

FLAUM, Circuit Judge.

This appeal raises the issue of whether the tax return preparer negligence penalty, section 6694(a) of the Internal Revenue Code,1 can be assessed against a preparer who understates income tax liability because he relied solely on information supplied to him by the taxpayers. The Internal Revenue Service ("IRS") assessed a penalty against appellant John Brockhouse. Pursuant...

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