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TODD v. UNITED STATES

Civ. A. No. 84-251.

617 F.Supp. 253 (1985)

Burt K. TODD and Frances Hays Todd, Plaintiffs v. UNITED STATES of America, Defendant.

United States District Court, W.D. Pennsylvania.

May 29, 1985.

Attorney(s) appearing for the Case

William J. Smith, Lawrence E. Flatley, Reed Smith Shaw & McClay, Pittsburgh, Pa., for plaintiffs.

Thomas A. Daley, Judith Giltenboth, Asst. U.S. Attys., Pittsburgh, Pa., Gregory S. Hrebiniak, U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION

TEITELBAUM, Chief Judge.

I.

Plaintiffs brought this action under the Internal Revenue Code of 1954, as amended, 26 U.S.C. §§ 1 et seq., seeking to recover federal income taxes and interest thereon, which plaintiffs contend was erroneously and illegally assessed and collected by the Internal Revenue Service (IRS).

A nonjury trial on this matter was conducted on January 14-15, 1985.

Judgment in...

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