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BROUNSTEIN v. U.S.

No. 92-1154.

979 F.2d 952 (1992)

Lou BROUNSTEIN, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Third Circuit.

Decided September 3, 1992.

Attorney(s) appearing for the Case

Gerald A. Inglesby, Merchantville, N.J., for appellant.

James A. Bruton, Acting Asst. Atty. Gen., Michael M. Baylson, U.S. Atty., Gary R. Allen, Bruce Ellisen, Sara S. Holderness, Scott P. Towers, U.S. Dept. of Justice, Tax Div., Washington, D.C., for appellee.

Before HUTCHINSON, COWEN and SEITZ, Circuit Judges.

Submitted Under Third Circuit Rule 12(6) August 20, 1992.

HUTCHINSON, Circuit Judge.

Appellant, Lou Brounstein (Brounstein), appeals an order of the United States District Court for the Eastern District of Pennsylvania granting summary judgment in favor of appellee United States of America on Brounstein's claim for a partial refund of an amount Brounstein paid on an Internal Revenue Service (IRS) penalty assessment and for IRS on its counterclaim for other...

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