MEMORANDUM AND ORDER
SACHS, District Judge.
This case, filed in 1978 after some fifteen years of administrative proceedings, is a suit for a tax refund, to recover $461,958.02 in taxes assessed for the years 1962-1970 and paid under protest in 1977. Plaintiff Midwest Research Institute (MRI) is a private not-for-profit corporation that is organized and operated for "scientific ... purposes" and thus enjoys a tax exemption pursuant to 26 U.S.C. § 501...
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