HALFHILL v. U.S. I.R.S.

Civil Action No. 95-484.

927 F.Supp. 171 (1996)

Ernest HALFHILL, d/b/a Halfhill Trucking, Plaintiff, v. UNITED STATES of America INTERNAL REVENUE SERVICE, Defendant.

United States District Court, W.D. Pennsylvania.

March 7, 1996.


Attorney(s) appearing for the Case

Stephen I. Richman, Ceisler, Richman & Smith, Washington, PA, Gerald P. Duff, Lodge L. Hanlon, John G. Paleudis, Todd M. Kildow, Hanlon, Duff, Paleudis & Estadt, St. Clairsville, OH, for plaintiff.

Michelle O. Gutzmer, United States Attorney's Office, Pittsburgh, PA, Charles M. Flesch, Robert S. Attardo, United States Department of Justice, Tax Division, Washington, DC, for United States of America Internal Revenue Service.


MEMORANDUM OPINION

BLOCH, District Judge.

Presently before the Court is defendant's motion for partial summary judgment. For the reasons set forth in this opinion, the Court will grant the defendant's motion.

I. Background

The facts of record are as follows.

In 1978, plaintiff purchased a tractor trailer and started a trucking company called Halfhill Trucking (HT), a sole proprietorship. Plaintiff operated HT as a...

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