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STANDARD OFFICE BLDG. CORP. v. UNITED STATES

No. 81 C 6158.

640 F.Supp. 549 (1986)

STANDARD OFFICE BUILDING CORPORATION, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Illinois, E.D.

June 11, 1986.

Attorney(s) appearing for the Case

Brian J. McKenna, Alan E. Bain, Daniel J. Westerbeck, Orval M. Adam, Chicago, Ill., for plaintiff.

Michael O'Connell, Asst. U.S. Atty., Chicago, Ill., Terri E. Schapiro, Michael J. Weitzner, Trial Attys., Tax Div., Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION

GRADY, Chief Judge.

This tax refund case involves difficult questions pertaining to the interpretation of two sections of the tax code, 26 U.S.C. §§ 3231(a) and 6051(a) and (c). The case is before us on the parties' cross-motions for summary judgment as to the liability of the plaintiff taxpayer, Standard Office Corporation ("Standard"), for assessments made by the government against it pursuant to the Railroad Retirement Tax...

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