MEMORANDUM OF DECISION AND ORDER
KELLEHER, District Judge.
This is an action for refund of federal income taxes in the amount of $868,170 brought by MCA Inc. and Universal City Studios, Inc., against the United States with respect to plaintiffs' tax liability for calendar years 1972 and 1973. The matter is before the Court on the parties' cross motions for summary judgment.
The issue presented for determination by the Court is whether the local outlets...
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