THIRD ORDER ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND ORDER DENYING PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
JAMES L. ROBART, District Judge.
I. INTRODUCTION
This matter comes before the court for a third time on Defendant Internal Revenue Service's ("IRS") motion for summary judgment (Dkt. # 32) and for the first time on Plaintiff William P. Shannahan's motion for summary judgment (Dkt. # 58). Previously, this court twice determined that the...
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