Lovell v. United States

MEMORANDUM AND ORDER

SHABAZ, District Judge.

The Court has previously denied summary judgment in these consolidated cases because the defendant had failed to dispel the notion of the existence of disputed facts relative to the requirements of 26 U.S.C. § 6702. Defendant has filed a new motion for summary judgment which highlights documentary facts that resolve any genuine issues of fact. Accordingly, summary judgment will be granted.

FACTS

The facts previously set forth in the Court’s order of January 30, 1984 are hereby adopted for purposes of this decision. In addition, the Court notes the…