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GOULDING v. U.S.

No. 90-1788.

957 F.2d 1420 (1992)

Randall S. GOULDING, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided March 18, 1992.

Attorney(s) appearing for the Case

Randall S. Goulding (argued) and George N. Leighton, Neal & Associates, Chicago, Ill., for plaintiff-appellant.

Thomas P. Walsh, Ira H. Raphaelson, Asst. U.S. Attys., Office of the U.S. Atty., Crim. Div., Chicago, Ill., Gary R. Allen, James K. Wilkens, Robert S. Pomerance (argued), Teresa T. Milton, Dept. of Justice, Tax Div., Appellate Section, and Thomas R. Jones, Dept. of Justice, Tax Div., Appellate Section, Washington, D.C., for defendant-appellee.

Before WOOD, Jr., FLAUM, and RIPPLE, Circuit Judges.

RIPPLE, Circuit Judge.

Randall Goulding was retained to act as the attorney for several limited partnerships. Mr. Goulding prepared the partnership returns and the Schedules K-1 for each partnership. Under Treasury Regulation § 301.7701-15(b)(3), the IRS deemed Mr. Goulding the preparer of the returns of the limited partners and assessed penalties against Mr. Goulding under 26 U.S.C. § 6694 for the negligent preparation of those returns. Mr. Goulding challenged...

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