District Court, E.D. New York October 23, 1981, 78 C 2799 (Silberberg v. United States)

MEMORANDUM OF DECISION AND ORDER

NEAHER, District Judge.

Plaintiff (“Silberberg”) commenced this action to challenge a 100% penalty assessment in the sum of $15,037.29 made against him by the Commissioner of Internal Revenue under §§ 6672 and 6671 of the Internal Revenue Code of 1954 (“Code”), and to recover $140.76 he paid in partial satisfaction thereof.