DECISION AND ORDER ON MOTION FOR PARTIAL SUMMARY JUDGMENT
ROBERT D. MORGAN, District Judge.
This is an action for refund of federal income taxes paid by plaintiffs as transferees of Best Advertising Corp. (BEST), a dissolved Illinois corporation. The court has jurisdiction under 28 U. S.C. § 1346(a) (1). Pending for decision is a motion by the Government for partial summary judgment, under Rule 56(d), F.R.Civ.P.
The following facts are undisputed...
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