MEMORANDUM OPINION AND ORDER
CONLON, District Judge.
Plaintiff Eliot A. Landau ("Landau") filed this action to obtain a refund of $100.00 plus interest that he paid to the Internal Revenue Service ("the IRS") as partial payment on a claim for unpaid taxes. Defendant United States of America ("the government") filed a counterclaim seeking judgment against Landau for the $56,774.70 balance in unpaid taxes plus...
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