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F.E. SCHUMACHER CO., INC. v. U.S.

Nos. 1:01CV0979, 5:02CV150, 5:02CV1569.

308 F.Supp.2d 819 (2004)

F.E. SCHUMACHER COMPANY, INC., Plaintiff, v. The UNITED STATES of America, Defendant.

United States District Court, N.D. Ohio, Eastern Division.

January 23, 2004.

Attorney(s) appearing for the Case

Andrew Agati, Squire, Sanders & Dempsey, Mark J. Valponi, Stephen M. Nechemias, Peter M. Poulos, Stephen H. Jett, Taft, Stettinius & Hollister, Kenneth A. Bravo, Ulmer & Berne, Cleveland, OH, for Plaintiff.

Michael W. Davis, Alejandro L. Bertoldo, United States Department of Justice, Washington, DC, for Defendant.

MEMORANDUM OF OPINION

MANOS, District Judge.

On January 10, 2001, F.E. Schumacher Company, Inc., Plaintiff, filed a Complaint against the United States of America, Defendant, seeking judicial review of an Internal Revenue Service (hereinafter, IRS) collection due process determination affirming the imposition of a tax penalty in the amount of $30,094.80 plus interest (Docket No. 1, Case No. 1:01CV097).1 The assessment...

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