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UNITED STATES v. NESLINE

Civ. A. No. M-79-1768.

590 F.Supp. 884 (1984)

UNITED STATES of America v. Joseph A. NESLINE.

United States District Court, D. Maryland.

July 12, 1984.

Attorney(s) appearing for the Case

J. Frederick Motz, U.S. Atty., D.Md., Baltimore, Md., Thomas M. Lawler, Tax Div., U.S. Dept. of Justice, Washington, D.C., for plaintiff.

Vincent J. Fuller, Kendra E. Heymann, and Williams & Connolly, Washington, D.C., Andrew Jay Graham and Kramon & Graham, P.A., Baltimore, Md., for defendant.

MEMORANDUM AND ORDER

JAMES R. MILLER, Jr., District Judge.

The United States brought this action, pursuant to 28 U.S.C. §§ 1340, 1345 and I.R.C. § 7402, to recover taxes allegedly owed by the defendant, Joseph A. Nesline, for the tax years 1971 and 1972. The defendant has filed a motion for judgment on the pleadings,1 Rule 12(e), Fed.R.Civ.P., and the United States has moved for summary judgment,

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