MEMORANDUM
FRANK GRAY, Jr., District Judge.
This civil action was instituted by Woodmont Terrace, Inc. (hereinafter called plaintiff) against the United States of America (hereinafter called defendant) for recovery of an alleged over-payment of federal corporate income taxes. It is now before the court on the motions of both parties for summary judgment.
Plaintiff was at all times relevant to this controversy a Tennessee corporation with its principal...
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