Lea v. United States

882 F. Supp. 687 (1995)

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Lea v. United States

United States District Court for the Western District of Tennessee
882 F. Supp. 687 (1995)

Facts

William Lea (plaintiff) was an accountant. In August 1987, Lea was convicted of seven counts of aiding and abetting the filing of false tax returns. Lea’s misconduct helped cause more than $160,000 in tax losses to the United States (defendant). Additionally, the United States devoted substantial resources investigating Lea and bringing him to trial. Lea was sentenced to prison and was fined $1,000 for each of the seven counts. In March 1990, the Internal Revenue Service (IRS) imposed a $34,000 civil penalty against Lea pursuant to 26 U.S.C. § 6701. This penalty was later reduced to $22,000. Lea sued the United States, alleging that the civil penalty (1) was barred by the statute of limitations and (2) violated the Double Jeopardy Clause of the Fifth Amendment to the United States Constitution because it was punitive. The United States moved for summary judgment on the grounds that (1) there was no statute of limitations regarding the initial assessment of a civil penalty pursuant to § 6701 and (2) the civil penalty was remedial and thus did not violate the Double Jeopardy Clause.

Rule of Law

Issue

Holding and Reasoning (Todd, J.)

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