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KUCHAN v. U.S.

No. 87 C 11.

679 F.Supp. 764 (1988)

William T. KUCHAN, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Illinois, E.D.

February 16, 1988.

Attorney(s) appearing for the Case

Joseph A. Lamendella, Kris Daniel, Lamendella & Daniel, Chicago, Ill., for plaintiff.

Martin B. Lowery, Asst. U.S. Atty., Office of Special Litigation Tax Div., U.S. Dept. of Justice, Alice J. Davis, Noreene C. Stehlik, Washington, D.C., for defendant.

MEMORANDUM OPINION

KOCORAS, District Judge:

This dispute concerns the interpretation and application of § 6701 of the Internal Revenue Code of 1954, as amended (the "Code"). 26 U.S.C.A. It is presently before the court on defendant's motion for partial summary judgment and plaintiff's motion for summary judgment. For the reasons contained herein, defendant's motion is granted and plaintiff's motion is denied...

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