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HIRSHFIELD v. U.S.

No. 99 CIV. 1828(RWS).

177 F.Supp.2d 220 (2001)

Stuart HIRSHFIELD and Susanne Hirshfield, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, S.D. New York.

November 19, 2001.

Attorney(s) appearing for the Case

Stuart A. Smith, Esq., New York City, for Plaintiffs.

Honorable Mary Jo White, United States Attorney for the Southern District of New York, New York City, By Sean H. Lane, Assistant U.S. Attorney, Of Counsel, for United States of America.

OPINION

SWEET, District Judge.

Plaintiff Stuart Hirshfield and his wife, Susanne Hirshfield (the "Hirshfields"), have moved under Local Civil Rule 6.3 for reconsideration of the opinion of this Court dated May 30, 2001 (the "Opinion"), holding that it had no jurisdiction to consider their claim that the IRS notice for penalty and related interest was time-barred and that it was subject to the doctrine of res judicata. For the reasons set forth below...

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