ORDER
G. KENDALL SHARP, District Judge:
This case was tried on October 10, 1989, without a jury. Based on the facts agreed to by the parties in their joint-pretrial stipulation, the testimony, and the evidence admitted at trial, this court enters the following findings of fact and conclusions of law pursuant to Federal Rule of Civil Procedure 52(a).
I. FINDINGS OF FACT
The United States of America brought this civil action under 26 U.S...
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