DECISION AND ORDER ON CROSS MOTIONS FOR SUMMARY JUDGMENT
ROBERT D. MORGAN, Chief Judge.
This is a suit for refund of federal income taxes because of alleged overpayments for 1972, 1973, 1974 and 1975 by plaintiff. The Government defends on the ground that the limitation of Section 6511(b)(2)(A) of the Internal Revenue Code of 1954 (26 U.S.C. § 6511(b)(2)(A)) precludes allowance of such refund. The parties agree that proper interpretation of Section...
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