MEMORANDUM AND ORDER DENYING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND GRANTING PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
COLLINSON, District Judge.
This is an action to recover penalties and interest in the sum of $15,846.73 which defendant assessed and collected from the estate of James G. Lusk. This amount was collected because the estate tax return was not filed on time. The case pends on cross-motions for summary judgment.
Under the provisions...
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