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  5. 297 F.Supp.2d 909 (2004)
 

HARRIGILL v. U.S.

No. CIV.A.3:03-CV-367BN.

297 F.Supp.2d 909 (2004)

Susan C. HARRIGILL Plaintiff v. UNITED STATES of America Defendant

United States District Court, S.D. Mississippi, Jackson Division.

January 20, 2004.

Attorney(s) appearing for the Case

Jamie G. Houston, III, John V. Eskrigge, Edward L. Carlisle, Watkins & Eager, Jackson, MS, for Susan C. Harrigill, plaintiff.

Cynthia Stier, U.S. Dept. of Justice— Tax Division, Washington, DC, Dunn Lampton, U.S. Attorney's Office, Gulfport, MS, for United States of America, defendant.

OPINION AND ORDER

BARBOUR, District Judge.

This cause is before the Court on the Motion for Summary Judgment of Defendant United States of America (hereinafter "IRS"1). Having considered the Motion and Response, as well as supporting and opposing authority, the Court finds that the Motion for Summary Judgment is not well taken and should be denied.

I. BACKGROUND FACTS AND PROCEDURAL HISTORY

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