OPINION ON MOTION FOR SUMMARY JUDGMENT
LAURENCE E. HOWARD, Chief Judge.
This matter is before the court on the motion for the Plaintiff, George M. Dewberry, for summary judgment. The following procedural and factual history appears to be uncontroverted from the pleadings, affidavits, exhibits and admissions of the parties.
The Plaintiff commenced this adversary proceeding against the United States challenging the assessment under 26 U.S.C...
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