MEMORANDUM OF OPINION AND ORDER
KRENZLER, District Judge.
Plaintiff Sifco Industries, Inc. (Sifco) filed its complaint in this action on July 14, 1982, seeking a refund of a tax penalty which Sifco alleges was illegally assessed and collected from it. Jurisdiction is conferred upon this Court by 28 U.S.C. § 1346(a)(1).
The parties have stipulated the facts in this action and submitted the action to the Court on the legal issue of whether Sifco...
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