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BRENNAN v. C.I.R.

Civ. A. No. 83CV-6295-AA.

581 F.Supp. 28 (1984)

Martin A. BRENNAN, Plaintiff, v. COMMISSIONER OF INTERNAL REVENUE, Defendant. John L. BRENNAN, Plaintiff, v. COMMISSIONER OF INTERNAL REVENUE, Defendant.

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

March 9, 1984.

Attorney(s) appearing for the Case

John L. Brennan, pro se.

Martin A. Brennan, pro se.

Seth G. Heald, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., Geneva S. Halliday, Asst. U.S. Atty., Detroit, Mich., for defendant.

MEMORANDUM OPINION AND ORDER

JOINER, District Judge.

Both of the above entitled actions have been brought by taxpayers to obtain a refund. In each case the I.R.S. assessed a $500 penalty against the taxpayer for filing a frivolous income tax return under 26 U.S.C. § 6702. Each taxpayer paid $75 and then filed for a refund. The refund was denied and the taxpayers are now separately appealing that decision.

As a preliminary matter, the Commissioner...

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