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GIBBS v. C.I.R.

Civ. A. No. CV87-PT-0507-M.

673 F.Supp. 1088 (1987)

Ruth Hand GIBBS and William Chadwick Gibbs, Plaintiffs, v. COMMISSIONER OF the INTERNAL REVENUE SERVICE, et al., Defendants.

United States District Court, N.D. Alabama, Middle Division.

July 30, 1987.

Attorney(s) appearing for the Case

William Chadwick Gibbs, pro se.

Ruth H. Gibbs, pro se.

Frank W. Donaldson, U.S. Atty., Caryl P. Privett, Asst. U.S. Atty., Birmingham, Ala., Lance J. Wolf, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., for defendants.

MEMORANDUM OPINION

PROPST, District Judge.

This matter is before the court upon defendant's Motion to Dismiss filed on June 18, 1987 and converted by the court into a motion for summary judgment.

The facts giving rise to this matter are briefly stated as follows:

William Chadwick Gibbs (Gibbs) failed to file income tax returns for the taxable years 1976 through 1979, inclusive. The Internal Revenue Service reconstructed his income for the...

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