Solitron Devices, Inc. v. United States

The judgment of the district court is affirmed for the reasons set forth in its Final Order of Summary Judgment entered on March 31, 1988 and appended hereto.

APPENDIX

FINAL ORDER OF SUMMARY JUDGMENT

MARCUS, District Judge.

THIS CAUSE has come before the Court upon the Defendant’s motion for summary judgment. The Defendant raises two bases for summary judgment: the limited jurisdiction of a district court over a matter that has been before the Tax Court under 26 U.S.C. § 6512(a) and res judicata. For the reasons set forth below, we GRANT the Defendant’s motion for summary judgment.

I. Facts

The…