MEMORANDUM OPINION
HARPER, District Judge.
Plaintiff, United States of America, brought this action under 26 U.S.C. § 7405(b) to recover refunds of federal income taxes allegedly erroneously issued to defendant, American Institute of Marketing Systems (hereinafter referred to as "New" AIMS), in the amount of $55,239.11, plus interest thereon as provided under 26 U.S.C. § 6602. This Court has jurisdiction under 28 U.S.C. §§ 1340 and 1345...
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