BEDROSIAN v. THE UNITED STATES OF AMERICA, DEPARTMENT OF THE TREASURY, INTERNAL REVENUE SERVICE

Filing 87

ORDERED AS FOLLOWS THAT THE COURT FINDS THAT ARTHUR BEDROSIANS ACTIONS WERE WILLFUL WITHIN THE MEANING OF 31 U.S.C. § 5321 AND WITH RESPECT TO THE AMOUNT OF THE PENALTY TO BE IMPOSED, THE COURT WILL REQUIRE THE PARTIES TO CONFER PROMPTLY AND THE N FILE EITHER A JOINT STATEMENT ON THIS ISSUE, OR SEPARATE STATEMENTS (LIMITED TO FIVE PAGES DOUBLE-SPACED) SETTING FORTH THEIR ARGUMENTS WITHIN TEN (10) DAYS. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 12/4/20. 12/4/20 ENTERED AND COPIES E-MAILED.(jaa, )

Case 2:15-cv-05853-MMB Document 87 Filed 12/04/20 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ARTHUR BEDROSIAN
v.

CIVIL ACTION
NO. 15-5853

THE UNITED STATES OF AMERICA,
DEPARTMENT OF THE TREASURY,
INTERNAL REVENUE SERVICE
ORDER ON REMAND FROM THIRD CIRCUIT
AND NOW, this 4th day of December, 2020, upon consideration of the Supplemental
Briefing by Defendant the United States (ECF 75), a response by Plaintiff Arthur Bedrosian (ECF
76), and a reply by the United States (ECF 77), and for the reasons stated in the attached
memorandum, it is hereby ORDERED as follows:
1. The Court finds that Arthur Bedrosian’s actions were willful within the meaning of 31
U.S.C. § 5321.
2. With respect to the amount of the penalty to be imposed, the Court will require the
parties to confer promptly and then file either a joint statement on this issue, or separate
statements (limited to five pages double-spaced) setting forth their arguments within
ten (10) days.

BY THE COURT:
s/ Michael M. Baylson
_______________________________
MICHAEL M. BAYLSON, U.S.D.J.

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