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TESHER v. U.S.

No. 02 Civ. 7445(LAK).

246 F.Supp.2d 297 (2003)

Martin TESHER, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

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

February 24, 2003.

Attorney(s) appearing for the Case

Jeffrey M. Herrmanm, New York City, for Plaintiff.

Nicole L. Gueron, Assistant United States Attorney, James B. Comey, United States Attorney, for Defendant.

MEMORANDUM OPINION

KAPLAN, District Judge.

This is an action to reverse a 2002 decision by the Internal Revenue Service, which declined a request by plaintiff to set aside a Notice of Federal Tax Lien ("NFTL") filed against him by the IRS to collect, pursuant to the United States— Canada Income Tax Convention ("UCITC"), Canadian taxes owed by plaintiff. Defendant has moved to dismiss the complaint for failure to state a claim upon which relief may...

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