Court of Appeals for the Sixth Circuit May 14, 1986, 85-5124, 85-5182 (Tennessee Baptist Children's Homes, Inc. And Dr. Evans B. Bowen, Cross-Appellants v. United States of America, Cross-Appellee)

KRUPANSKY, Circuit Judge.

Defendant-appellant the Government appealed the district court’s order, 604 F.Supp. 210, denying its motion for judgment notwithstanding a jury verdict in favor of plaintiffs in this tax action to recover penalties and interests assessed by the Internal Revenue Service (IRS). Plaintiffs-cross-appellants Tennessee Baptist Children's

Homes, Inc.