ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT
HORTON, District Judge.
Plaintiff, a furniture manufacturer in Memphis, Tennessee, filed this civil action against the United States seeking a refund of $97,163.87 in federal income taxes plus interest thereon. Plaintiff alleges the overpayment resulted from a requirement of the Commissioner of the Internal Revenue Service requiring plaintiff to change its method of...
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