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  5. 757 F.Supp.2d 877 (2010)
 

DAVID E. WATSON, P.C. v. U.S.

No. 4:08-cv-442.

757 F.Supp.2d 877 (2010)

DAVID E. WATSON, P.C., Plaintiff, v. UNITED STATES of America, Defendant.

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

December 23, 2010.

Attorney(s) appearing for the Case

Ronald L. Mountsier , Schneider Stiles Serangeli & Mountsier PC, Des Moines, IA, for Plaintiff.

Michael R. Pahl , U.S. Dept. of Justice Tax Division, Washington, DC, for Defendant.

ORDER ON BENCH TRIAL

ROBERT W. PRATT, Chief Judge.

On or about February 5, 2007, the United States of America ("Defendant" or "Government") recharacterized dividend and loan payments from David E. Watson, P.C. ("DEWPC" or "Plaintiff") to its sole shareholder and employee, David E. Watson ("Watson"), as wages. Compl. (Clerk's No. 1) ¶ 10. In light of this recharacterization, Defendant assessed additional employment taxes, interest and penalties against...

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