MEMORANDUM OPINION AND ORDER
ROBERT M. HILL, District Judge.
I. INTRODUCTION
The Producers Supply & Tool Company instituted this lawsuit against the United States for a tax refund. In its answer the Government asserted a setoff to Producers' claim. The setoff challenged the validity of an ABC oil and gas transaction entered into by Northwest Oil Company, a subdsidiary of Producers. The parties have since disposed of the issues raised in Producers...
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