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MELLINA v. U.S.

No. 4:06-CV-449-A.

518 F.Supp.2d 825 (2007)

George J. MELLINA, Jr., et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Texas, Fort Worth Division.

October 26, 2007.

Attorney(s) appearing for the Case

Thomas E. Redding, Sallie W. Gladney, Teresa Jean Womack, Redding & Associates, Houston, TX, for Plaintiffs.

Michael D. Powell, U.S. Department of Justice, Dallas, TX, for Defendant.

MEMORANDUM OPINION and ORDER

JOHN McBRYDE, District Judge.

In the instant action plaintiffs, George J. Mellina, Jr. ("Mellina") and Betty M. Mellina, seek a refund from defendant, United States of America, of penalty interest assessed by the Internal Revenue Service ("IRS") under 26 U.S.C. 6621(c), for the tax year 1986. Each party has filed a motion for summary judgment. For the reasons stated below, the court concludes that defendant's motion...

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