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POPKIN v. U.S.

Civ. A. No. 1:86-CV-2241-JOF.

699 F.Supp. 893 (1988)

Gerald M. POPKIN, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Georgia.

April 21, 1988.

Attorney(s) appearing for the Case

William E. Frantz, Frantz & Sanders, Atlanta, Ga., for plaintiff.

Sharon D. Stokes, Office of U.S. Atty., Atlanta, Ga., Noreen C. Stehlik, U.S. Dept. of Justice, Tax Div., Sp. Litigation Office, Washington, D.C., for defendant.

ORDER

FORRESTER, District Judge.

This suit for refund of income tax penalties is before the court on the plaintiff's motion for partial judgment on the pleadings and on the defendant's motion for partial summary judgment. The following facts are not in dispute. The Internal Revenue Service determined in 1986 that the plaintiff had participated in fifty-five sales of the O.E.C. Energy Corporation tax shelter in...

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