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SWAYZE v. UNITED STATES

Nos. 84-4375, 84-4376.

785 F.2d 715 (1986)

Darlene SWAYZE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee, Stuart MARTIN, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 21, 1986.

Attorney(s) appearing for the Case

Barbara J. Rose, Milwaukie, Or., for plaintiffs-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Richard Farber, Paul E. Pelletier, Washington, D.C., for defendant-appellee.

Before TANG and FARRIS, CIRCUIT JUDGES, and KELLEHER, District Judge.

KELLEHER, District Judge:

Darlene Swayze and Stuart Martin (appellants), both professional tax preparers, appeal from summary judgment in these consolidated actions. The IRS assessed penalties pursuant to 26 U.S.C. § 6694(a), charging that appellants had negligently or intentionally disregarded rules and regulations by preparing a number of so-called family trust tax returns. Appellants paid 15 percent of the assessed...

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