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McPHERSON v. U.S.

No. CV 08-47-M-DWM.

673 F.Supp.2d 1167 (2009)

Orma L. McPHERSON, Plaintiff, v. The UNITED STATES of America, Defendants.

United States District Court, D. Montana, Missoula Division.

September 29, 2009.

Attorney(s) appearing for the Case

Danielle Ann Rand Coffman, John B. Dudis, Crowley, Haughey, Hanson, Toole & Dietrich, Kalispell, MT, Thomas C. Morrison, Morrison & Balukas Law Firm, Helena, MT, for Plaintiff.

Adam F. Hulbig, Rickey Watson, U.S. Department of Justice, Washington, DC, for Defendants.

ORDER

DONALD W. MOLLOY, District Judge.

I. Introduction

Robert and Orma McPherson, Canadian citizens residing in Calgary, Alberta, have a vacation property on Flathead Lake in Poison, Montana, hereinafter called the "vacation property."1 The Government of Canada contends that Robert failed to pay taxes on income earned during years 1995-1998. The United States Internal Revenue Service ("IRS"), acting on behalf of the...

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