Gregory v. United States

MEMORANDUM AND OPINION

ROSENTHAL, District Judge.

In this tax refund suit, plaintiffs, M. Russell Gregory and Kay K. Gregory, allege that the Internal Revenue Service unlawfully assessed and collected taxes for partnership liabilities after the statute of limitations for making the assessments had expired. The parties have filed cross-motions for summary judgment on the issue of whether the Internal Revenue Service timely assessed the taxes at issue. (Docket Entry Nos. 10 & 14). Based on the motions, the pleadings, the record, and the applicable law, this court GRANTS the United States’ motion…