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INFORMATION RESOURCES, INC. v. U.S.

No. 91-1188.

950 F.2d 1122 (1992)

INFORMATION RESOURCES, INC., a Corporation, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

January 16, 1992.

Attorney(s) appearing for the Case

W.D. Masterson, Kilgore & Kilgore, Dallas, Tex., for plaintiff-appellant.

Marvin Collins, U.S. Atty., Louise P. Hytken, Asst. U.S. Atty., Tax Div., Dept. of Justice, Dallas, Tex., Gary R. Allen, Chief, Mary F. Clark, Robert S. Pomerance, Appellate Sec., Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before WILLIAMS, DUHÉ, and EMILIO M. GARZA, Circuit Judges.

JERRE S. WILLIAMS, Circuit Judge:

The Internal Revenue Service ("I.R.S.") erroneously filed tax liens against Information Resources, Inc. Information Resources brought suit for damages for both the erroneous filing of the liens and the failure to issue a timely release of the liens pursuant to 26 U.S.C. §§ 7432 and 7433. The district court granted the government's motion for summary judgment because Information Resources failed to exhaust its administrative...

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