Halfhill v. United States Internal Revenue Service
District Court, W.D. Pennsylvania
1Opinion of the Court
MEMORANDUM OPINION
BLOCH, District Judge.
Presently before the Court is defendant’s motion for partial summary judgment. For the reasons set forth in this opinion, the Court will grant the defendant’s motion.
I. Background
The facts of record are as follows.
In 1978, plaintiff purchased a tractor trailer and started a trucking company called Halfhill Trucking (HT), a sole proprietorship. Plaintiff operated HT as a leasing venture; that is, plaintiff leased HT’s truck to various interstate commerce carriers and also provided a truck driver who hauled loads for the carriers.
During 1978 and the first…
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