Ginter v. United States

ORDER

SCOTT O. WRIGHT, Senior District Judge.

Before this Court are, plaintiff’s motion for partial summary judgment, defendant’s memorandum opposing plaintiff’s motion, and defendant’s motion to dismiss Count II of plaintiff’s amended complaint. For the reasons set out below, plaintiff’s motion will be denied and defendant’s motion will be granted.

Background

Plaintiff in this case brought suit against the United States of America seeking a refund of taxes assessed and paid. During the period in issue, plaintiff operated a sole-proprietorship known as Mid-Mo Mobile Home Brokers. Plaintiff…