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AMERICAN TECHNOLOGY RESOURCES v. U.S.

Civ. A. No. 86-5769.

709 F.Supp. 610 (1989)

AMERICAN TECHNOLOGY RESOURCES, Albert S. Pitts, James A. Pitts and Thomas M. Pitts v. UNITED STATES of America.

United States District Court, E.D. Pennsylvania.

March 29, 1989.

Attorney(s) appearing for the Case

Howard Philip Newman, Wyncote, Pa., for plaintiffs.

Noreene C. Stehlik, Office of Special Litigation, Tax Div., Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OF DECISION UNDER FED.R.CIV.P. 52(a)

LUDWIG, District Judge.

In 1986, the Internal Revenue Service assessed penalties against plaintiffs American Technology Resources, Albert S. Pitts, James A. Pitts, and Thomas M. Pitts for promoting abusive tax shelters as to tax years 1982 and 1983. 26 U.S.C. § 6700. Pursuant to 26 U.S.C. § 6703(c), plaintiffs, having paid 15 percent of the penalties, filed this action contesting their liability....

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