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COLOSIMO v. U.S.

No. 4:08-CV-00397.

707 F.Supp.2d 926 (2010)

Charles A. COLOSIMO, Sr., Plaintiff, v. UNITED STATES of America, Defendant. Charles A. Colosimo and Carolyn Colosimo, Defendants on Counterclaim.

United States District Court, S.D. Iowa, Central Division.

February 16, 2010.

Attorney(s) appearing for the Case

James R. Monroe, Jerrold Alan Wanek, Robert C. Gainer, Garten & Wanek, Des Moines, IA, for Plaintiff.

Russell S. Clarke, Robert E. Fay, U.S. Dept. of Justice, Tax Division, Washington, DC, for Defendant.

ORDER

JOHN A. JARVEY, District Judge.

I. PROCEDURAL BACKGROUND

A. Pleadings

On January 1, 2007, the IRS assessed trust fund recovery penalties of $711,234.82 against Charles Colosimo ("Colosimo"), Carolyn Colosimo ("Carolyn"), and Andrew Gillaspey ("Gillaspey") pursuant to 26 U.S.C. §§ 6671 and 6672. On September 19, 2008, Colosimo filed a Claim for Refund and Abatement with the IRS in Minneapolis, requesting a...

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