OPINION AND ORDER GRANTING DEFENDANT'S MOTION TO AFFIRM
CLELAND, District Judge.
On November 1, 2006, Plaintiffs Stearn & Company, LLC ("Stearn & Co.") and Steven Stearn ("Stearn") initiated this action, seeking to set aside the Internal Revenue Service Office of Appeal's ("Office of Appeals's") determination. Currently pending before the court is Defendant Internal Revenue Service's ("IRS's") April 20, 2007 motion to affirm the Office of Appeals...
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