RULING ON CROSS MOTIONS FOR SUMMARY JUDGMENT
NEVAS, District Judge.
The plaintiff, Thomas A. Johnson ("Johnson"), brings this action pro se against the United States to obtain a refund of amounts collected and applied to his tax liabilities for the 1984 tax year by the Internal Revenue Service ("IRS"). Johnson contends that the IRS failed to make a legal assessment on December 19, 1991 against his 1984 tax year.
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