No. 88-1668.

881 F.2d 340 (1989)

PLANNED INVESTMENTS, INC., Michigan Corporation, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided August 10, 1989.

Attorney(s) appearing for the Case

Thomas A. Klug (argued), Okemos, Mich., for plaintiff-appellee.

John A. Smietanka, U.S. Atty., Grand Rapids, Mich., Jonathan S. Cohen (argued), U.S. Dept. of Justice, Tax Div. Appellate Section, Washington, D.C., Gary R. Allen, Acting Chief, William S. Rose, Jr., Asst. Atty. Gen., Jane S. Kimball, Dept. of Justice, Tax Div., Washington, D.C., S. Hollis Fleischer, Washington, D.C., for defendant-appellant.

Before: ENGEL, Chief Judge, MERRITT and KRUPANSKY, Circuit Judges.

MERRITT, Circuit Judge.

The issue in this tax case is the adequacy of the notice sent by the Internal Revenue Service ("IRS" or "Government") to inform plaintiff, Planned Investments, Inc. ("PI") that it had been assessed a penalty of $64,000 under § 6700 of the Internal Revenue Code ("Code"), 26 U.S.C. § 6700, for PI's promotion of an abusive tax shelter. The District Court, finding that the notice was inadequate and unfair because it did not clearly specify...

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