MEMORANDUM OF DECISION AND ORDER
BENSON, Chief Judge.
This is a suit by the University of North Dakota (University) to recover from the United States taxes alleged to have been erroneously and illegally assessed and collected by the Internal Revenue Service (IRS). Defendant has interposed a counterclaim. The matter was submitted to the court on a stipulation of facts and taken under advisement upon the filing of briefs. For reasons hereinafter stated, judgment...
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