KNOX, District Judge.
This is an action at law to recover interest and penalties paid by the petitioner to the United States pursuant to a compromise agreement. The plaintiff has moved for summary judgment, and the defendant has made a cross-motion for dismissal of the complaint on the grounds that the court has no jurisdiction of the subject-matter of the action, and that, on the merits, the plaintiff is entitled to no relief.
The facts as stipulated by the...
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