WOLFE v. UNITED STATES

No. CV-82-227-BLG.

612 F.Supp. 605 (1985)

Charles E. WOLFE, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Montana, Billings Division.

May 22, 1985.


Attorney(s) appearing for the Case

Jack W. Burnett, Billings, Mont., for plaintiff.

John D. Steffan, Tax Div., Dept. of Justice, Washington, D.C., Lorraine D. Gallinger, Asst. U.S. Atty., Billings, Mont., for defendant.


MEMORANDUM OPINION

BATTIN, Chief Judge.

This case is before the Court on cross-motions for summary judgment. For the reasons stated below, the defendant's motion is granted and the plaintiff's motion is denied.

FACTS AND PROCEDURE

The facts of this case are not in dispute. The parties have filed an extensive stipulation of facts with the Court.

Charles E. Wolfe was the sole shareholder...

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