MEMORANDUM
FRANK W. WILSON, Chief Judge.
This is an action for the refund of federal taxes. Jurisdiction of the Court is invoked pursuant to 28 U.S.C. § 1346 and is not in dispute. The case is presently before the Court upon the motion of the defendant for summary judgment.
The following facts have been stipulated by the parties. Orthopaedic Associates, P. C., is a professional corporation for the practice of medicine organized and existing...
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