MEMORANDUM AND ORDER
KANE, District Judge.
Before the Court is Defendant's motion for partial summary judgment. The motion has been fully briefed and is ripe for disposition. For the reasons set forth below, the motion is granted.
I. Background
On March 16, 1998, Plaintiffs Wade and Cindy Bloom filed a complaint seeking damages pursuant to 26 U.S.C. §§ 7432 and 7433 for the alleged improper failure of...
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