District Court, W.D. Tennessee July 28, 2004, 03-2882 D/P (Pollack v. United States)

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ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

DONALD, District Judge.

Before the Court is the motion of the United States of America (“Defendant”) for summary judgment. Barry S. Pollack (“Plaintiff’) brings this case pursuant to 26 U.S.C. § 6330(d) for judicial review of a Notice of Determination by the Internal Revenue Service (“IRS”).