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MID-SOUTH MUSIC CORP. v. KOLAK

No. 83-5867.

756 F.2d 23 (1984)

MID-SOUTH MUSIC CORPORATION, Plaintiff-Appellant, v. Alvin H. KOLAK, Sid Wissand, Harvey Haskins, Rose Baumgarter, Chris Workman, Charles Stamphill, Bruce Thomas, Darrell Hall, Roy Oakes, Tommy Kain, and the United States of America, Defendants-Appellees.

United States Court of Appeals, Sixth Circuit.

Decided October 30, 1984.

Attorney(s) appearing for the Case

John B. Link, III (Lead), John B. Owens, Jr. (argued), King, Ballow & Little, Nashville, Tenn., for plaintiff-appellant.

Robert E. Rice, Glenn L. Archer, Jr., Michael L. Paup, Thomas Gick (argued), U.S. Dept. of Justice, Tax Div.-Civil Trial Section, Washington, D.C., for defendants-appellees.

Before MERRITT and KRUPANSKY, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

MERRITT, Circuit Judge.

Plaintiff Mid-South Music Corporation, appeals from the District Court's dismissal of its suit against the United States and various officials of the Internal Revenue Service seeking compensatory and punitive damages for alleged violation of its statutory and constitutional rights. The alleged violations arose from a pre-filing letter sent by IRS officials in Nashville to investors in a tax shelter marketed by Mid-South, informing them that...

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