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CLARK v. U.S.

No. CIV.A.1:98-CV-1425-JOF.

171 F.Supp.2d 1341 (2001)

John E. CLARK and Catherine P. Clark, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Georgia, Atlanta Division.

February 28, 2001.

Attorney(s) appearing for the Case

James Alan Gober, Arnall Golden & Gregory, Atlanta, GA, Stuart A. Smith, phv, Law Offices of Stuart A. Smith, New York City, for plaintiffs.

Mary Christine Roemer, Robert David Powell, Office of United States Attorney, Northern District of Georgia, Atlanta, GA, Michael N. Wilcove, phv-USDOJ, U.S. Department of Justice, Tax Division, Washington, DC, for defendant.

ORDER

FORRESTER, District Judge.

This matter is before the court on Defendant's motion for summary judgment [33] and Defendant's motions to supplement same [35, 43].

I. Statement of the Case

A. Procedural History

Plaintiffs, John E. Clark and Catherine P. Clark, brought the instant action against the United States to recover federal income tax, interest, and penalties which they assert were illegally assessed and collected...

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