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PARRISH v. LOEB

No. 81-4072.

558 F.Supp. 921 (1982)

Gale L. PARRISH, Executor of the Estate of Abigail R. Parrish, deceased, Plaintiff, v. Ira S. LOEB, District Director of the Internal Revenue Service, and the United States of America, Defendants.

United States District Court, C.D. Illinois.

November 23, 1982.

Attorney(s) appearing for the Case

George H. Brinkmann, Howard, Brinkmann & Kolom, Monmouth, Ill., for plaintiff.

Michael J. Weitzner, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., Janet L. Jannusch, Asst. U.S. Atty., Peoria, Ill., for defendants.

DECISION AND ORDER

ROBERT D. MORGAN, Senior District Judge.

This suit seeks to challenge the application by the District Director of Internal Revenue of the provisions of 26 U.S.C. § 6166, and attendant revenue rulings, to a state of facts which are not contested. Jurisdictional considerations are deemed to be dispositive of issues now before the court. The relevant, uncontested facts, taken from the pleadings and from the content of an affidavit filed...

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