BILZERIAN v. USA

No. 95-2744.

86 F.3d 1067 (1996)

Paul A. BILZERIAN, Plaintiff, Terri L. Steffen, Plaintiff-Appellant, v. USA, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

July 1, 1996.


Attorney(s) appearing for the Case

Cindy L. LoCicero, Gibbs & Runyan, P.A., B. Gray Gibbs, St. Petersburg, FL, for appellant.

James B. Thompson, Jr., U.S. Dept. of Justice, Tax Division, Washington, D.C., Gary R. Allen, Tax Div., Dept. of Justice, Sally J. Schornstheimer, Loretta C. Argrett, David English Carmack, Washington, DC, for appellee.

Before EDMONDSON and DUBINA, Circuit Judges, and LOGAN, Senior Circuit Judge.


PER CURIAM:

Terri Steffen appeals the district court's order granting summary judgment to the Internal Revenue Service ("IRS") on her claim for damages under 26 U.S.C. § 7432. We reverse and remand for a determination of damages, if any.

Background

Steffen and her husband Paul Bilzerian ("Plaintiffs") timely filed their 1985 joint tax return. In October 1989, the IRS sent Plaintiffs a notice...

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