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GIBSON v. U.S.

No. CV 90-5390 SVW (GX).

761 F.Supp. 685 (1991)

David A. GIBSON and Jean E. Jaros (formerly Jean E. Gibson), Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, C.D. California.

April 4, 1991.

Attorney(s) appearing for the Case

Robert B. Martin, Jr., Martin & Hudson, Pasadena, Cal., for plaintiffs.

Mason C. Lewis, Asst. U.S. Atty., Los Angeles, Cal., for defendant.

MEMORANDUM OF DECISION

WILSON, District Judge.

INTRODUCTION

Plaintiffs filed this action to enjoin the Internal Revenue Service ("IRS") from collecting past due taxes, interest, and penalties allegedly owed by plaintiffs for the tax years 1980, 1981, and 1983. The basis for plaintiffs' action is that the IRS failed to provide the plaintiffs with proper notice of the deficiency prior to the running of the statute of limitations for the tax years...

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