Wolfe v. United States

MEMORANDUM OPINION

BATTIN, Chief Judge.

This case is before the Court on cross-motions for summary judgment. For the reasons stated below, the defendant’s motion is granted and the plaintiff’s motion is denied.

FACTS AND PROCEDURE

The facts of this case are not in dispute. The parties have filed an extensive stipulation of facts with the Court.

Charles E. Wolfe was the sole shareholder and president of Wolfe & Company (corporation), a corporation which leased tractor-trailers. Charles E. Wolfe also operated a business as a proprietorship known as Charles E. Wolfe d/b/a Evergreen Express…