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STEVENS v. U.S.

No. 1:93-CV-483.

859 F.Supp. 1110 (1994)

John L. STEVENS and Mitchell H. Stevens, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Michigan.

March 23, 1994.

Attorney(s) appearing for the Case

Mitchell H. Nelson, Grand Haven, MI, for plaintiffs.

Daniel M. LaVille, Asst. U.S. Atty., Michael H. Dettmer, U.S. Atty., Grand Rapids, MI, Doris D. Coles, U.S. Dept. of Justice, Tax Div., Washington, DC, for defendant.

OPINION

BENJAMIN F. GIBSON, Chief Judge.

This matter is before the Court on defendant United States of America's motion to dismiss pursuant to Federal Rule of Civil Procedure 12. For the reasons stated below, the defendant's motion is granted.

I.

Although the parties have characterized them differently, the facts pertaining to this motion are essentially not disputed. As of April 1989, the Internal Revenue Service had assessed unpaid...

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