MEMORANDUM OPINION AND ORDER
CROWLEY, District Judge.
This is an action for recovery of wholesale liquor dealers occupational taxes, penalties and interest assessed and collected pursuant to the Internal Revenue Code of 1954. This Court has jurisdiction under 28 U.S.C. § 1346. Plaintiff 672 Corporation alleges that it is not a wholesale dealer within the purview of 26 U.S.C. § 5111(a) and, therefore, is not liable for the wholesale liquor dealers...
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