MEMORANDUM OPINION
MICHAEL, District Judge.
The plaintiffs, Williams Home and Miller Home, in this consolidated action, come before this court seeking a refund of Federal Excise Taxes paid under 26 U.S.C. § 4940. The Williams Home, who for all relevant times has been engaged in maintaining a retirement home for women aged 55 and older, seeks a refund for fiscal years ending August 31, 1971 through August 31, 1978. The Miller Home, who for all relevant...
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