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DAVIS v. C.I.R.

Civ. A. No. 86-T-303-N.

661 F.Supp. 733 (1987)

William P. DAVIS and Virginia O. Davis, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent.

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

February 13, 1987.

Attorney(s) appearing for the Case

Laura Lee, Billings, Mont., for petitioners.

John C. Bell, U.S. Atty., D. Broward Segrest, Asst. U.S. Atty., Montgomery, Ala., Lance J. Wolf, Atty., Tax Div., Dept. of Justice, Washington, D.C., for respondent.

MEMORANDUM OPINION

MYRON H. THOMPSON, District Judge.

In this action, petitioners William Davis and Virginia Owens (formerly Davis) seek to have the court enjoin the Commissioner of the Internal Revenue Service (IRS) from collecting taxes and penalties assessed against them for the year 1980. The cause is now before the court on respondent Commissioner's motion for summary judgment. For reasons that follow, the court is of the opinion that the motion is...

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