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TALEN v. U.S. EX REL. C.I.R.

No. CIV.A. 03-00846(RMC).

355 F.Supp.2d 22 (2004)

Waldemar & Michelle TALEN, Plaintiffs, v. UNITED STATES of America, By and through, COMMISSIONER OF ITERNAL REVENUE, Defendant.

United States District Court, District of Columbia.

October 27, 2004.

Attorney(s) appearing for the Case

Richard Edward Preston, Alvin Brown & Associates, Fairfax, VA, for Plaintiffs.

Jennifer Lynn Vozne, U.S. Department of Justice Tax Division, Washington, DC, for Defendant.

MEMORANDUM OPINION

COLLYER, District Judge.

Plaintiffs, Waldemar & Michelle Talen, challenge a Tax Lien Filing by the Internal Revenue Service ("IRS" or "Service") arising out of their positions as responsible officers of Talen & Talen, Inc., and Trust Fund Recovery Penalties owed by that business. The Talens seek to challenge the underlying liability that led to the tax lien. Defendant...

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