MEMORANDUM AND ORDER
SACHS, District Judge.
Plaintiff Uniformed Benefit Services Association (USBA) filed suit against the defendant United States of America (Government), seeking a refund of $712,155.61 in taxes and interest. The parties have submitted the case to the court on stipulated facts. The following statement of facts is drawn from that stipulation.
The plaintiff seeks a refund of taxes paid for the 1978 and 1979 tax years. During those...
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