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U.S. v. DONOVAN

No. 02-3260

348 F.3d 509 (2003)

UNITED STATES of America, Plaintiff-Appellant, v. Patrick M. Donovan, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: October 31, 2003.

Attorney(s) appearing for the Case

ON BRIEF: Robert J. Branman, David English Carmack, UNITED STATES DEPARTMENT OF JUSTICE, TAX DIVISION, APPELLATE SECTION, Washington, D.C., for Appellant.

Irving Bell, Cleveland, Ohio, for Appellee.

Before: BOGGS, Chief Circuit Judge; GILMAN, Circuit Judge; and MARBLEY, District Judge.

Pursuant to Sixth Circuit Rule 206

OPINION

BOGGS, Chief Circuit Judge.

The United States appeals the order of summary judgment entered by the district court, dismissing its complaint against Patrick Donovan, in which it sought to reduce to judgment certain tax assessments. For the following reasons, we reverse and remand to the district court so that it may enter summary judgment in favor of the government.

I

Donovan was a responsible...

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