MEMORANDUM OPINION AND ORDER
SOFAER, District Judge:
In this action, pursuant to 28 U.S.C. § 1346(a)(1), Hershel Krasnow seeks a refund of federal income taxes paid for the years ending December 31, 1968 and December 31, 1971. The Government has moved for partial summary judgment dismissing certain of plaintiff's claims. The motion is granted.
In mid-1970, Hershel Krasnow decided to invest in a small brokerage firm, the Kern Securities Corporation...
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