ORDER GRANTING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT ORDER DENYING MOTION FOR PROTECTIVE ORDER AS MOOT AND ORDER GRANTING DEFENDANT'S MOTION FOR COSTS AND ATTORNEY FEES
GIBBONS, District Judge.
Plaintiff, William Carroll, filed a complaint seeking to invalidate the determination by the Internal Revenue Service (IRS) to proceed with collection by levy on the penalty imposed pursuant to 26 U.S.C. § 6702(a). On January 22, 2002, the defendant filed its...
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