MEMORANDUM OPINION AND RULINGS
VIETOR, Chief Judge.
Plaintiffs Ruan Financial Corporation and Ruan Transport Corporation (jointly referred to as "Ruan") brings suit seeking a refund of federal manufacturer's excise taxes, interest and penalties, on 12 highway tractors. Defendant United States of America counterclaims seeking federal manufacturer's excise taxes, plus interest and penalties, on an additional 414 highway tractors. Both parties move for summary...
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