MEMORANDUM
TAKASUGI, District Judge.
This memorandum decision is filed pursuant to Rule 52(a), Federal Rules of Civil Procedure.
FACTS
Plaintiff David initiated this action seeking a refund of employment taxes, penalties and interest assessed against Grand Care Inc. ("GCI"), a California corporation, excluding any sums representing withholding and Federal Insurance Contribution Act ("FICA") taxes deducted from the wages of GCI employees...
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