JUDISCH v. UNITED STATES

No. 83-3238.

755 F.2d 823 (1985)

Clara Mann JUDISCH, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

March 20, 1985.


Attorney(s) appearing for the Case

Michael L. Paup, Richard Farber, Joan I. Oppenheimer, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellant.

Curtis J. Timm, Sarasota, Fla., for plaintiff-appellee.

Before TJOFLAT and HATCHETT, Circuit Judges, and GARZA, Senior Circuit Judge.


TJOFLAT, Circuit Judge:

Section 6694(a) of the Internal Revenue Code, 26 U.S.C. § 6694(a) (1982),1 imposes a penalty on an income tax preparer2 who understates a taxpayer's liability on an income tax return by negligently or intentionally disregarding revenue rules and regulations. Section 6694(b) of the Code, 26 U.S.C. § 6694(b) (1982),3 penalizes a tax preparer who willfully...

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