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USA FINANCIAL SERVICES, INC. v. U.S. I.R.S.

No. CIV.A. 1:05-1092.

459 F.Supp.2d 440 (2006)

USA FINANCIAL SERVICES, INC., Plaintiff, v. UNITED STATES of America INTERNAL REVENUE SERVICE, Defendant.

United States District Court, E.D. Virginia, Alexandria Division.

August 2, 2006.

Attorney(s) appearing for the Case

Aaron Robert Caruso, Abod & Caruso, Rockville, MD, for Plaintiff.

Gerard J. Mene, Robert K. Coulter, United States Attorney's Office, Alexandria, VA, for Defendant.

MEMORANDUM ORDER

LEE, District Judge.

THIS MATTER is before the Court on Defendant, the Internal Revenue Service's ("IRS") Motion for Summary Judgment of USA Financial Services, Inc.'s ("USA FSI") appeal of a collection due process hearing ("CDP"). This is a tax collection case where the delinquent taxpayer, USA FSI contends that the IRS's Appeals Officer abused his discretion by rejecting USA FSI's proposed installment payment agreement for unpaid...

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