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ALLGLASS SYSTEMS, INC. v. C.I.R.

No. Civ.A. 03-4772.

330 F.Supp.2d 540 (2004)

ALLGLASS SYSTEMS, INC., et al., Plaintiffs, v. COMMISSIONER OF INTERNAL REVENUE, Defendant.

United States District Court, E.D. Pennsylvania.

August 17, 2004.

Attorney(s) appearing for the Case

Bruce Bellingham, Daniel J. Dugan, Spector, Gadon & Rosen, PC, Philadelphia, PA, for Plaintiffs.

Jill R. Ortelt, U.S. Department of Justice, Washington, DC, for Defendant.

MEMORANDUM

ROBRENO, District Judge.

Plaintiffs, AllGlass Systems, Inc., East Coast Fabricators, LLC, and ASI Southeast, LLC (collectively "taxpayers") filed this action, seeking review of the Internal Review Service's ("IRS") issuance of three Notices of Determination Concerning Collection Action under Internal Revenue Code ("IRC") Sections 6320 and/or 6330. There is no dispute as to taxpayers' liability to the IRS for employment taxes not paid in 2000 and...

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