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liability for the Federal income tax deficiencies and the
additions to tax for fraud imposed against petitioners under
section 6653(b)." Id. at 187. The same reasoning applies here.
Indeed, the Sixth Circuit's opinion in Alt disposed of the Eighth
Amendment point summarily, stating at F.3d , :
Because we hold that the tax penalties awarded
against Alt are not "punishment," there is no need to
address Alt's claim that the penalties constitute an
excessive fine under the Eighth Amendment. Like the
Double Jeopardy Clause, the Excessive Fines Clause only
protects against "punishment," * * * [citations
omitted]
We hold that the petitioner's Eighth Amendment argument adds
nothing to his case.
Decisions will be entered
for respondent.
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