OPINION
LUONGO, District Judge.
This is an action by a corporate taxpayer for a refund of federal income taxes pursuant to 26 U.S.C. § 7422. The material facts are not in dispute, and the taxpayer and the government have filed cross-motions for partial summary judgment.
Plaintiff Lion Associates, Inc. (Lion) was incorporated in 1972, at which time it became the parent and sole stockholder of two subsidiary corporations, Masonry Resurfacing and...
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