ALEXANDER HARVEY, II, District Judge.
In this civil action, plaintiff is seeking a refund of certain taxes which it alleges have been erroneously or illegally assessed and collected by the Internal Revenue Service (hereinafter the "IRS"). The plaintiff, STA of Baltimore — ILA Container Royalty Fund (hereinafter the "Fund") is here asserting that it is entitled to refunds of certain taxes it paid pursuant to the Federal Insurance Contributions Act, 26 U.S.C...
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