Rule 37(c)(1) Sanctions — Failure to Exclude Unnecessary Evidence That Was Improperly Undisclosed Properly Not Sanctioned Due to Absence of Prejudice [= Evidence of Harmlessness]

Janet Walcott appeals the district court's grant of summary judgment to the government on her claim that the Internal Revenue Service (IRS) failed to send her the required notices of deficiency before it levied on her income to collect taxes and penalties. Exercising jurisdiction under 28 U.S.C. § 1291, we a ...

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