Spivak v. United States (370 F.2d 612, 1967)

United States Court of Appeals for the Second Circuit 1967-01-04

Citations

Full opinion text

J. JOSEPH SMITH, Circuit Judge:

Ben D. Spivak and David S. Shapiro appeal from a May 16, 1966 judgment of the United States District Court for the Southern District of New York, Richard H. Levet, Judge, which dismissed their complaint for a refund of taxes and awarded the United States $27,192.27 with interest and costs on its counterclaim for 100% penalties pursuant to §§ 6672 an