Hirschhorn v. United States

MEMORANDUM OPINION AND ORDER

HAIGHT, District Judge:

This is an action challenging a termination assessment made by the Internal Revenue Service (“IRS”) against plaintiff Ronald Hirschhorn. Defendant United States of America (hereafter the “Government”) moves “for an Order dismissing the complaint”, without specifying the rule or statute upon which the motion is predicated. See Local Civil Rule 3(d). Because the parties have supplied affidavits and exhibits in support of and in opposition to the present motion, I treat it as one brought pursuant to F.R.Civ.P. 56. Jurisdiction is based on 26…