MEMORANDUM AND ORDER
ANN ALDRICH, District Judge.
In this civil tax refund action, the parties have filed cross-motions for summary judgment pursuant to Fed.R.Civ.P. 56(c). Upon consideration of the pleadings, affidavits, and exhibits, this Court denies the plaintiff's Motion, grants the defendant's Motion, and dismisses the complaint.
Jurisdiction rests upon 28 U.S.C. § 1346(a)(1).
I.
The relevant facts are not disputed. The...
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