MEMORANDUM
JOHN T. NIXON, District Judge.
Plaintiff consolidated taxpayer, Thomas Nelson, Inc. ("TNI") and its subsidiary, Thomas Nelson Publishing Company ("TNP"), brought this action against the defendant United States of America ("the Government") for the recovery of federal income taxes, penalties, and interest paid for the fiscal year ending March 31, 1982. A jury trial was held on February 16-18, 1988. At the close of the evidence, both parties moved...
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