MEMORANDUM AND ORDER
ALLEN SHARP, Chief Judge.
The plaintiff taxpayer filed a complaint for refund under 28 U.S.C. § 1340 and 26 U.S.C. § 7402(a) on September 13, 1983. The plaintiff filed motion for summary judgment on December 9, 1983 and a pretrial conference was held in open court on April 6, 1984. Defendant filed motion for summary judgment on February 22, 1984. Said motions are now ripe for ruling.
This case involves a $500 civil...
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