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ALLIANCE SERVICES, INC. v. U.S. EX REL. C.I.R.

No. 1:04-CV-12-BBM.

363 F.Supp.2d 1367 (2005)

ALLIANCE SERVICES, INC., Plaintiff, v. UNITED STATES of America by and through the COMMISSIONER OF INTERNAL REVENUE SERVICE, Defendant.

United States District Court, N.D. Georgia, Atlanta Division.

February 10, 2005.

Attorney(s) appearing for the Case

David Decoursey Aughtry, Chamberlain Hrdlicka White Williams & Martin, Atlanta, GA, for Plaintiff.

Michael N. Wilcove, U.S. Department of Justice Tax Division, Washington, DC, for Defendant.

ORDER

MARTIN, District Judge.

This matter is before the court on the Defendant's Motion for Partial Summary Judgment [Doc. No. 19] and Plaintiff's Cross-Motion for Summary Judgment [Doc. No. 23].1

I. Factual and Procedural History

Plaintiff Alliance Services, Inc. ("Alliance"), a Georgia corporation, formerly had two lines of business: (1) providing security guard services...

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