District Court, N.D. Alabama July 30, 1987, Civ. A. CV87-PT-0507-M (Gibbs v. Commissioner of the Internal Revenue Service)

MEMORANDUM OPINION

PROPST, District Judge.

This matter is before the court upon defendant’s Motion to Dismiss filed on June 18, 1987 and converted by the court into a motion for summary judgment.

The facts giving rise to this matter are briefly stated as follows:

William Chadwick Gibbs (Gibbs) failed to file income tax returns for the taxable years 1976 through 1979, inclusive.