PER CURIAM:
At issue is whether the § 6213(d) waiver of the restrictions on assessment and collection of a deficiency in the settlement agreement between Kathleen and Noel Pilie and the Internal Revenue Service suspended the imposition of interest because the IRS did not make a timely demand of payment. The district court, by summary judgment, held that it did not; we AFFIRM.
I.
The Pilies were partners in Barrister Equipment Associates 88,...
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