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SIANO v. U.S.

Civil Action No. 95-1618.

948 F.Supp. 479 (1996)

Russell L. SIANO, Lorraine I. Siano, Peter V. Marcoline, Jr., and Susan N. Marcoline, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Pennsylvania.

September 12, 1996.

Attorney(s) appearing for the Case

Peter V. Marcoline, Jr., Pittsburgh, PA, for plaintiffs.

Michael C. Colville, United States Attorney's Office, Pittsburgh, PA, R. Scott Clarke, United States Department of Justice, Tax Division, Washington, DC, for defendant.

MEMORANDUM OPINION

BLOCH, District Judge.

Presently before this Court are cross-motions for summary judgment filed by plaintiffs and defendant pursuant to Fed.R.Civ.P. 56. For the reasons set forth in this opinion, this Court will grant defendant's motion and deny plaintiffs' motion.

I. Factual background

This is an action for the recovery of taxes assessed against plaintiffs under the Internal Revenue Code. The uncontroverted...

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