MEMORANDUM OPINION
DIAMOND, District Judge.
This is a tax refund action in which the plaintiff-taxpayer seeks a refund of certain interest accrued on an excise tax imposed pursuant to I.R.C. § 4975(c) (1982). Although the plaintiff acknowledges liability for the excise tax, he challenges the defendant's statutory authority under the Internal Revenue Code ("Code") to impose the accrued interest.
Presently before the court are cross-motions for...
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