MEMORANDUM DECISION
TASHIMA, District Judge.
This is an income tax refund action in which plaintiffs The Parsons Corporation and The Ralph M. Parsons Company (collectively "Parsons") seek a refund of $571,914, plus statutory interest. The taxpayers allege that the taxes at issue were assessed and collected illegally. Both Parsons and the government have moved for summary judgment. The parties agree that this dispute is appropriate for resolution by summary...
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