MEMORANDUM OPINION AND ORDER
JOINER, District Judge.
Plaintiff General Motors Corporation (GM) brings this action to recover interest from the United States under section 6611(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 6611(a), on certain amounts of federal excise tax erroneously assessed against, collected from, and later returned to GM. This court has jurisdiction under 28 U.S.C. § 1346(a). Both parties have moved for summary judgment...
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