ORDER
SANDERS, District Judge.
This is a civil action for the refund of taxes paid in partial satisfaction of a 100 per cent penalty assessed against Plaintiff J.W. McGinty ("McGinty"). The Defendant, the United States of America (the "Government"), counterclaimed for the amount of the penalty which remains unpaid plus interest. The case is currently before the Court on cross motions for summary judgment filed by the parties on December 23, 1982; stipulated...
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