DECISION
SAM, District Judge.
Plaintiff Balanced Financial Management (BFM) brought this action against defendants the United States, the Internal Revenue Service (IRS) and the District Director of the IRS. The matter was first heard by the Magistrate on the parties' cross motions for summary judgment, and is now before the court on BFM's objection to the Magistrate's report and recommendation that summary judgment be granted for the Government.
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