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INTERSPORT FASHIONS WEST, INC. v. UNITED STATES

No. 07-739 T.

INTERSPORT FASHIONS WEST, INC., Plaintiff, v. THE UNITED STATES, Defendant.

United States Court of Federal Claims.

October 29, 2008.

Attorney(s) appearing for the Case

Donald Rightnour, McLean, VA, for plaintiff.

Jacob E. Christensen, with whom were Nathan J. Hochman, Assistant Attorney General, David Gustafson, Chief, and Steven I. Frahm, Assistant Chief, Court of Federal Claims Section, Tax Division, United States Department of Justice, Washington, DC, for defendant.

Motion to Dismiss for Lack of Subject Matter Jurisdiction; Validity of Tax Assessment; Full Payment Rule; 26 U.S.C. § 6203; 26 C.F.R. § 301.6203-1; RCFC 12(b)(1)

EMILY C. HEWITT, District Judge.

OPINION AND ORDER

Before the court are defendant's Motion of the United States to Dismiss in Part (defendant's Motion or Def.'s Mot.), plaintiff's Response to Motion of the United States to Dismiss in Part (plaintiff's Response or Pl.'s Resp....

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