Summary
granting Government's motion for summary judgment and imposing "per activity" penalty where taxpayer failed to adduce evidence that he derived less than $1,000 for each tax avoidance package sold
Summary of this case from Schulz v. United StatesOpinion
No. 10-1626.
Submitted: May 31, 2011.
Decided: June 7, 2011.
Appeal from the United States District Court for the District of South Carolina, at Greenville. G. Ross Anderson, Jr., Senior District Judge. (6:08-cv-03760-GRA).
J. Bradley Bennett, Salvini Bennett, LLC, Greenville, South Carolina, for Appellant. John A. DiCicco, Acting Assistant Attorney General, Steven Parks, Kenneth W. Rosenberg, United States Department of Justice, Washington, D.C., for Appellee.
Before WILKINSON, KEENAN, and WYNN, Circuit Judges.
Affirmed by unpublished PER CURIAM opinion.
Unpublished opinions are not binding precedent in this circuit.
John Howard Alexander appeals from the district court's order granting summary judgment in favor of the Government on its action seeking (1) to reduce to judgment assessments made against Alexander for federal income tax and related penalties; and (2) to foreclose upon certain real property titled in the name of the Alexander Family Trust. We have reviewed the record included on appeal, as well as the parties' briefs, and we find no error in the district court's judgment. Accordingly, we affirm for the reasons stated by the district court. United States v. Alexander, No. 6:08-cv-03760-GRA, 2010 WL 1643425 (D.S.C. Apr. 28, 2010). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process.
AFFIRMED.