MEMORANDUM AND ORDER
KRUPANSKY, District Judge.
This is an action instituted by the plaintiff, the First Federal Savings and Loan Association of Cleveland (First Federal), as successor in interest to the Keystone Savings and Loan Company (Keystone), pursuant to § 7422(a) of the Internal Revenue Code of 1954 (the Code), 26 U.S.C. § 7422(a), to recover federal income taxes in the amount of $353,912.79 plus $86,490.98 assessed interest paid by the...
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