MEMORANDUM AND ORDER
WEBB, District Judge.
Plaintiff, Vance Wiertzema, was assessed and paid additional federal income tax for the taxable year 1983, after receiving a statutory Notice of Deficiency. Plaintiff had filed a claim for refund which was denied April 28, 1987.
Both plaintiff and defendant have moved for summary judgment in this case.
Facts
The parties have stipulated to certain facts. The pertinent facts are set...
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