ORDER
W. EARL BRITT, Senior District Judge.
This matter is before the court on the United States' motion for summary judgment. (DE # 27.)
I. BACKGROUND
On 11 January 2013, plaintiff Charlotte K. Webb-Smith ("Webb-Smith") commenced a claim of refund action against the Internal Revenue Service pursuant to 26 U.S.C. § 7422. (DE # 1.) Plaintiff seeks a refund for taxes paid and abatement of civil penalties assessed against her pursuant...
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