United States Court of Appeals, Sixth Circuit.
MILBURN, Circuit Judge.
Plaintiff Wiley appeals the district court's denial of his motion for summary judgment and the grant of summary judgment to defendant United States of America. On appeal, the issue is whether there is a genuine issue of material fact as to whether the Internal Revenue Service mailed the statutorily required notice of deficiency to plaintiff. For the reasons that follow, we affirm the denial of summary judgment to the plaintiff and reverse the...
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