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COLLINS v. U.S.

Nos. 87-5580, 87-5581.

848 F.2d 740 (1988)

Francis A. COLLINS, Plaintiff-Appellee (87-5580), Plaintiff-Appellant (87-5581), v. UNITED STATES of America, Defendant-Appellant (87-5580), Defendant-Appellee (87-5581).

United States Court of Appeals, Sixth Circuit.

Decided June 8, 1988.

Attorney(s) appearing for the Case

Paul M. Predmore, Trial Atty., Tax Div., U.S. Dept. of Justice, Michael L. Paup, Chief, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., Roger M. Olsen, Michael C. Durney, Richard Farber, Nancy Morgan (argued), James C. Thomason, III, Asst. U.S. Atty., Nashville, Tenn., for defendant-appellant, defendant-appellee.

Dennis W. Powers (argued), McClellan, Powers and Ehmling, Gallatin, Tenn., for plaintiff-appellee, plaintiff-appellant.

Before NELSON and NORRIS, Circuit Judges, MARKEY, Chief Circuit Judge.

PER CURIAM.

The government appeals from an order of the district court denying its motion for judgment notwithstanding the verdict, after a jury had rendered its verdict in favor of the taxpayer, Francis A. Collins, in his suit contesting the assessment against him of approximately $18,000 for unpaid taxes withheld from the earnings of employees of Stinger Boats, Inc. The Internal Revenue Service had determined that Collins...

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