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ZIKRIA v. WILLIAMS

Civ. A. No. 81-250.

535 F.Supp. 481 (1982)

Emir A. ZIKRIA, and Khalida B. Zikria, Plaintiffs, v. William E. WILLIAMS, Acting Commissioner of Internal Revenue Service, Thomas Davis, District Director of the Internal Revenue Service, and Leonard C. Russo, Revenue Agent, Internal Revenue Service, Defendants.

United States District Court, W. D. Pennsylvania.

March 5, 1982.

Attorney(s) appearing for the Case

Richard H. Martin, Pittsburgh, Pa., for plaintiffs.

Stephen W. Laramore, Trial Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., Thomas A. Daley, Asst. U. S. Atty., Pittsburgh, Pa., for defendants.

MEMORANDUM

McCUNE, District Judge.

This is an action brought by taxpayers, seeking to enjoin the IRS from collecting taxes and penalties assessed against them for the years 1973 and 1974. The case comes before us now on cross-motions for summary judgment. In accordance with Federal Rule of Civil Procedure 56(c), we proceed to examine "the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits," to determine...

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