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MESSINGER v. U.S.

Civ. A. No. HAR-90-303.

769 F.Supp. 935 (1991)

Edward C. MESSINGER, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Maryland.

July 22, 1991.

Attorney(s) appearing for the Case

Peter Driscoll, Columbia, Md., for plaintiffs.

Richard D. Bennett, U.S. Atty., Larry D. Adams, Asst. U.S. Atty., Baltimore, Md., Edward J. Snyder, Michael J. Kearns, Michael J. Salem, U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION

HARGROVE, District Judge.

Presently before this Court are cross-Motions for Summary Judgment filed by the parties in this case. The issues have been fully briefed. The material facts are not in dispute. A full hearing was held on these Motions in open court.

FACTS

On December 29, 1988, the Internal Revenue Service's ("IRS") Philadelphia Service Center issued to Plaintiffs Edward C. Messinger and Joan S. Messinger ("Messingers...

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