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VISHNEVSKY v. UNITED STATES

No. 74-C-547.

430 F.Supp. 648 (1977)

John VISHNEVSKY and Margaret Vishnevsky, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E. D. Wisconsin.

April 21, 1977.

Attorney(s) appearing for the Case

Sherwin C. Peltin, Peregrine, Marcuvitz, Cameron, Peltin, Hersh & Lensky, S. C., Milwaukee, Wis., for plaintiffs.

Gerald A. Kafka, Trial Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., William J. Mulligan, U. S. Atty., Milwaukee, Wis., for defendant.

MEMORANDUM AND ORDER

WARREN, District Judge.

This cause is presently before the Court on cross-motions for summary judgment. Fed.R.Civ.P. 56. The parties have conceded that there are no genuine issues as to any material fact and that judgment may be entered as a matter of law.1

The facts may be briefly summarized as follows. In a letter dated July 10, 1972, the Internal Revenue Service issued a notice of deficiency to...

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