MEMORANDUM ORDER
DENNIS R. KNAPP, District Judge.
Plaintiff filed this action on November 3, 1981, pursuant to the provisions of 28 U.S.C. § 1346(a)(1), for the recovery of federal income taxes, plus interest, alleged to have been erroneously and improperly assessed by the defendant. The matter is presently pending before the Court on cross-motions for summary judgment. The undisputed facts of this case are as follows:
Plaintiff, a West Virginia...
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