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SPRINGFIELD v. U.S.

No. 95-55270.

88 F.3d 750 (1996)

Martin L. SPRINGFIELD, dba Douglas Motors, Plaintiff-Counter-Defendant-Appellant, v. UNITED STATES of America, Defendant-Counter-Claimant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 3, 1996.

Attorney(s) appearing for the Case

Patricia A. Isaacs, El Cajon, California, for plaintiff-counter-defendant-appellant.

Anthony T. Sheehan, Department of Justice, Washington, DC, for defendant-counter-claimant-appellee.

Before: REINHARDT, KOZINSKI, and HAWKINS, Circuit Judges.

MICHAEL DALY HAWKINS, Circuit Judge:

When the government ignores a taxpayer's contentions as to the real world conditions of the marketplace, despite the requirements of Congress that it consider them, it invites the result reached here.

Martin L. Springfield brought this action to recover various employment taxes, penalties and interest paid under protest for the tax quarter ending September 30, 1986. The government counterclaimed for the balance of the assessments...

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