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FRIKO CORP. v. I.R.S.

No. 93-109-CIV.

872 F.Supp. 966 (1994)

FRIKO CORPORATION, Plaintiff, v. INTERNAL REVENUE SERVICE, Defendant.

United States District Court, S.D. Florida.

September 28, 1994.

Attorney(s) appearing for the Case

Donald Lee Ferguson, Boca Raton, FL, Montgomery Blair Sibley, Miami, FL, for plaintiff.

Jose Francisco De Leon, U.S. Dept. of Justice, Tax Div., Washington, DC, for defendant.

MEMORANDUM OPINION

FERGUSON, District Judge.

THIS CAUSE came before the Court for a nonjury trial on August 25, 1994. The sole issue to be tried was plaintiff's claim for damages, pursuant to section 7433 of the Internal Revenue Code, for unauthorized collection actions. After hearing argument of counsel, the Court makes the following findings of fact and conclusions of law.

FINDINGS OF FACT

On May 4, 1994, the...

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