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KELLY v. U.S.

No. 4:01CV1803JCH.

209 F.Supp.2d 981 (2002)

Billy R. KELLY, Petitioner, v. UNITED STATES of America, Respondent.

United States District Court, E.D. Missouri, Eastern Division.

April 19, 2002.

Attorney(s) appearing for the Case

Billy R. Kelly, St. Clair, MO, pro se.

Raymond W. Gruender, III, Office of U.S. Atty., St. Louis, MO, Michael R. Pahl, U.S. Dept. of Justice, Office of Sp. Litigation, Tax Div., Washington, DC, for U.S.

MEMORANDUM AND ORDER

HAMILTON, District Judge.

This matter is before the court pursuant to the Motion for Summary Judgment filed by Respondent United States of America. See Doc. 9. Petitioner filed Objections. See Doc. 11. For the reasons set forth in this Memorandum and Order, the court grants the Motion for Summary Judgment.

UNCONTROVERTED FACTS

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