SPRIZZO, District Judge:
This is an action for a federal tax refund. See Complaint at ¶ IV. Defendant has moved for summary judgment and the parties have stipulated to a set of facts for the purposes of this motion. For the reasons set forth infra, the Court grants defendants' motion for summary judgment.
BACKGROUND
The facts in this action, as set forth in the parties' stipulation of facts ("Stipulation") and the exhibits attached...
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