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SPIROFF v. U.S.

No. 97-CV-75314-DT.

95 F.Supp.2d 673 (2000)

M. Craig SPIROFF and Susan E. Teubert, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Michigan, Southern Division.

January 27, 2000.

Attorney(s) appearing for the Case

Cheryl M. Warren, Northville, MI, for plaintiffs.

Susan E. Teubert, Dearborn, MI, pro se.

Thomas W. Cole, Sixbey, Friedman, Falls Church, VA, Thomas P. Cole, Department of Justice, Tax Division, Washington, DC, Pamela J. Thompson, United States Attorney's Office, Detroit, MI, Lawrence G. Willcox, U.S. Department of Justice, Tax Division, Washington, DC, for Internal Revenue Service, Department of the Treasury, United States Attorney General, United States Attorney, defendants.

OPINION AND ORDER

ZATKOFF, Chief Judge.

I. INTRODUCTION

This matter is before the Court on plaintiffs' and defendant's Motion for Summary Judgment. Since neither party specified which rule their respective motion was based upon, the Court will treat both motions as though they were brought pursuant to Fed.R.Civ.P. 56 because they rely upon matters outside of the pleadings. Both parties responded to the respective motions and neither party...

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