MEMORANDUM AND ORDER
SAFFELS, District Judge.
This matter is before the court on defendant's motion for summary judgment and plaintiff's motion for partial summary judgment. The court heard oral argument on these motions on January 3, 1986. This is a civil tax refund suit brought by plaintiff to recover railroad retirement taxes paid pursuant to provisions of the Railroad Retirement Tax Act of the Internal Revenue Code of 1954. These consolidated cases involve...
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