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COOK v. U.S.

Civ. A. No. 1:CV-90-519.

765 F.Supp. 217 (1991)

Dean A. COOK, Plaintiff, v. UNITED STATES of America, Defendant and Third Party Plaintiff, v. Nicholas SPITHOGIANIS, and Lawrence L. Cirillo, Third Party Defendants.

United States District Court, M.D. Pennsylvania.

May 29, 1991.

Attorney(s) appearing for the Case

David E. Lehman, Harrisburg, Pa., for Dean Cook.

Bruce Brandler, U.S. Attys. Office, Scranton, Pa., for U.S.

Bruce Brandler, U.S. Attys. Office, Scranton, Pa., Gregory D. Stefan, U.S. Dept. of Justice, Trial Atty., Tax Div., Washington, D.C., for the U.S.

Nicholas Spithogianis, pro se.

Lloyd R. Persun, Harrisburg, Pa., Christopher Charles Conner, Mette, Evans & Woodside, Christian Steven Daghir, Mette, Evans and Woodside, Harrisburg, Pa., for Lawrence L. Cirillo.

MEMORANDUM

CALDWELL, District Judge.

I. Introduction

This action arises pursuant to Section 6672 of the Internal Revenue Code (26 U.S.C. § 6672), which imposes penalties for failure of responsible persons to collect and pay over taxes to the United States. Plaintiff, Dean A. Cook, filed a complaint against the United States of America, to recover an amount paid in partial satisfaction of a § 6672 assessment against him, which he...

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