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U.S. v. DIXON

Civ. A. No. 86-H-22-N.

672 F.Supp. 503 (1987)

UNITED STATES of America, Plaintiff, v. Julian DIXON, Defendant.

United States District Court, M.D. Alabama, N.D.

July 1, 1987.

Attorney(s) appearing for the Case

Steven M. Kwartin, Jane Juliano, Trial Attys., John C. Bell, U.S. Atty., D. Broward Segrest, Asst. U.S. Atty., Lance J. Wolf, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., for plaintiff.

Arthur P. Tranakos, Atlanta, Ga., for defendant.

MEMORANDUM OPINION

HOBBS, Chief Judge.

The United States of America brought this action to recover unpaid federal income taxes for the year 1975 in the amount of $200,997.02, including interest and penalties. On May 22, 1987, the Government filed a motion for summary judgment supported by a document entitled "Certificate of Assessments and Payments." The defendant, Julian Dixon, has also filed a motion for summary judgment which raises

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