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KOROBKIN v. U.S.

No. 91-56243.

988 F.2d 975 (1993)

Frieda KOROBKIN; Leonard Korobkin; Leonard Korobkin Professional Corporation, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 12, 1993.

Attorney(s) appearing for the Case

John M. Youngquist, Titchell, Maltzman, Mark, Bass, Ohleyer & Mishel, San Francisco, CA, for plaintiffs-appellants Frieda Korobkin, Leonard Korobkin and Leonard Korobkin Professional Corp.

Edward DuMont, Asst. to the Sol. Gen., James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Jonathan S. Cohen, Paula K. Speck, Washington, DC, for defendant-appellee U.S.

Before: BROWNING, HUG and KOZINSKI, Circuit Judges.

PER CURIAM:

The Korobkins were allegedly involved in several abusive tax shelter transactions, and were assessed over $300,000 in penalties under I.R.C. § 6700. People who disagree with a penalty assessment can contest it by (1) paying 15% of the assessment and filing an administrative refund claim within 30 days of notice of the penalty, (2) waiting until the IRS denies the claim or until 6 months elapse (whichever is earlier), and (3) filing suit in district...

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