Hirschhorn v. United States

, MEMORANDUM OPINION AND ORDER

HAIGHT, District Judge:

On March 4, 1988 a hearing was held in the captioned action to determine:

“... whether or not [IRS Appeals Officer] Socha was able to acquire sufficient detail at ... [an IRS appeals conference with plaintiff's counsel] for the IRS to ascertain ‘that plaintiff [had or] had not previously filed tax returns____’”

Memorandum Opinion and Order dated February 9, 1988, slip op. at 2, quoting Memorandum Opinion and Order dated June 17, 1987, 662 F.Supp. 887, 891.

I considered this issue crucial for reasons explained in the prior opinions in this…