IN RE DEWBERRY

Bankruptcy No. HG 93-80051, Adv. No. 93-8024.

158 B.R. 979 (1993)

In re George M. DEWBERRY, Debtor. George M. DEWBERRY, Plaintiff, v. UNITED STATES of America, Defendant.

United States Bankruptcy Court, W.D. Michigan.

September 21, 1993.


Attorney(s) appearing for the Case

Jeffrey A. DeVree, Elizabeth K. Bransdorfer, Grand Rapids, MI, Donald A. Statland, Chicago, IL, for plaintiff.

Ruth Ann Ernst, Grand Rapids, MI, John V. Cardone, Alexandria Nicholaides, CTS, Northern Region, Tax Div., Dept. of Justice, Washington, D.C., Oksana Xenos, James Mauro, Dist. Counsel, IRS, Grand Rapids, MI, for defendant.


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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