MEMORANDUM AND ORDER
BARTLETT, District Judge.
This is a civil action against the United States of America for recovery of manufacturer's excise tax under Section 4061(a)(1) of the Internal Revenue Code of 1954, as amended, 26 U.S.C. § 4061(a)(1). Plaintiff alleges the taxes, penalties and interest at issue were erroneously paid, or erroneously or illegally assessed and collected. Plaintiff also seeks recovery of attorney's fees under the Civil Rights...
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