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COSTELLO v. U.S. GOVERNMENT

No. CV 90-6184 ER.

765 F.Supp. 1003 (1991)

John J. COSTELLO, Plaintiff, v. UNITED STATES GOVERNMENT, Defendant.

United States District Court, C.D. California.

May 24, 1991.

Attorney(s) appearing for the Case

Bruce I. Hochman and Steven Toscher, Hochman, Salkin & DeRoy, Beverly Hills, Cal., for plaintiff.

Lourdes G. Baird, U.S. Atty., Timothy M. Mulligan, Asst. U.S. Atty., Tax Div., Los Angeles, Cal., for defendant.

MEMORANDUM DECISION: DENYING DEFENDANT'S MOTION TO DISMISS; GRANTING DEFENDANT'S MOTION FOR JUDGMENT ON THE PLEADINGS; AND DENYING PLAINTIFF'S MOTION TO AMEND THE JUDGMENT

RAFEEDIE, District Judge.

INTRODUCTION

Plaintiff has brought suit against the United States to enjoin the Internal Revenue Service from assessing a tax deficiency against him. He claims that the intended assessment is barred by the statute of limitations applicable to partners...

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