MEMORANDUM OPINION
SUHRHEINRICH, District Judge.
This matter is before the Court on plaintiff's motion for summary judgment for refund of an overpayment of income tax in the Internal Revenue Service's (IRS) account in the name of Essiy Fink, deceased. The defendant has countered with a motion to dismiss plaintiff's complaint with prejudice or, in the alternative, for summary judgment.
Plaintiff is suing for a refund of income taxes for the years...
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