MEMORANDUM AND ORDER
SAFFELS, District Judge.
This matter is before the court on plaintiff's motion for summary judgment. This is an action to recover the refund of taxes assessed and collected by the defendant, United States of America. The United States filed a counterclaim against plaintiff seeking to collect taxes assessed on plaintiff under 26 U.S.C. § 6672.
The undisputed facts are as follows. On December 28, 1987, the Internal Revenue...
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