DECISION and ORDER
MYRON L. GORDON, District Judge.
This matter is before me on cross-motions for summary judgment. The parties are in agreement that there exists no genuine triable issue of any material fact and that decision must flow to one or the other as a matter of law. The motion of the plaintiff for summary judgment will be denied, and the motion of the defendant will be granted.
The Internal Revenue Service (IRS), acting pursuant to 26 U...
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