MEMORANDUM RULING
WALTER, District Judge.
Pending for determination are The Exploration Company of Louisiana, Inc.'s ("ECL") and the United States of America's cross motions for summary judgment. ECL contends it was disallowed a refund for windfall profit tax withheld for the year 1983 in the amount of $146,437.83. ECL claims that it is an "independent producer," and, therefore, is eligible for reduced tax rates for its tier 1 production and for the stripper...
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