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CONVERSE v. U.S.

No. 5:92 CV 1255.

839 F.Supp. 1274 (1993)

Maurice D. CONVERSE, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

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

August 23, 1993.

Attorney(s) appearing for the Case

J. Michael Gatien, Geiger, Teeple, Smith & Hahn, Alliance, OH, for plaintiffs.

Robert L. Handros, Washington, DC, for defendant.

MEMORANDUM OPINION

DOWD, District Judge.

The above-captioned case is before the Court on the joint stipulation of facts (Docket # 15) and briefs of the parties (Docket ## 17, 19, 20).

I. BACKGROUND1

Pursuant to an audit, by letter dated December 4, 1987, the District Director of Internal Revenue proposed deficiencies and penalties in the 1984 and 1985 income taxes2...

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