Opinion
CIVIL ACTION NO. H-00-1297
April 8, 2002
ORDER DENYING IRS'S § 6621 MOTION
This Court issued a Memorandum Opinion in this case on March 31, 2002. It has come to the attention of the Court that, contrary to the statements in footnotes 48 and 50 of that Memorandum Opinion, an affirmative motion for summary judgment related to 26 U.S.C. § 6621 was contained in the United States' Response to Plaintiff's Motion for Protective Order and United States' Motion for Partial Summary Judgment Based on Settlement Agreement ("IRS's § 6621 Motion") [Doc. #48].
The issues and arguments raised by the IRS's § 6621 Motion are filly addressed at 53-59 of the March 31, 2002 Memorandum Opinion. For the reasons stated in the 31, 2002 Memorandum Opinion, it is hereby
ORDERED that the United States' Motion for Partial Summary Judgment Based on Settlement Agreement [Doc. #48] is DENIED.