MEMORANDUM OPINION AND ORDER
GETZENDANNER, District Judge:
This action for a refund of federal taxes, brought pursuant to 28 U.S.C. § 1346(a), is before the court on the cross-motions for summary judgment of plaintiff Water Quality Association Employees' Benefit Corporation ("the Corporation") and defendant United States of America. In this action, the Corporation claims entitlement to a tax refund for taxes paid in 1981 by it and its predecessor, the...
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