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DEGUZMAN v. U.S.

No. CIV. 99-3318(WGB).

147 F.Supp.2d 274 (2001)

Danilo DeGUZMAN and Daisy DeGuzman, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. New Jersey.

May 24, 2001.

Attorney(s) appearing for the Case

Poe & Freireich, P.A., Jay J. Freireich, Michael J. Sullivan, Florham Park, NJ, for Plaintiffs.

Robert J. Cleary, United States Attorney, Susan Cassell, Assistant U.S. Attorney, U.S. Attorney's Office, District of New Jersey, Newark, NJ, Richard G. Jacobus, Gregory S. Hrebiniak, United States Department of Justice (Tax Division), Washington, DC, for Defendant.

OPINION

BASSLER, District Judge.

The United States of America ("Defendant") moves for summary judgement pursuant to Fed.R.Civ.P. 56. This Court has jurisdiction pursuant to 28 U.S.C. § 1346(a)(1). For the reasons set forth in this opinion, Defendant's motion for summary judgment is hereby granted.

BACKGROUND

A. PROCEDURAL HISTORY

On July 14, 1999, Mr. and Mrs. DeGuzman ("Plaintiffs") filed a complaint...

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