ORDER
BRETT, District Judge.
This matter comes before the Court on plaintiffs' Motion for Summary Judgment filed pursuant to Rule 56 of the Federal Rules of Civil Procedure. The Court heard oral arguments by counsel on June 17, 1983. For the reasons set forth below, plaintiffs' Motion is overruled.
This action arises from a dispute between the plaintiffs and the Internal Revenue Service regarding the characterization of money received by plaintiff...
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