MEMORANDUM AND ORDER
EARL E. O'CONNOR, Chief Judge.
This matter is before the court on cross-motions for summary judgment. Plaintiffs seek a refund of income taxes and interest penalties thereon assessed against them by the Internal Revenue Service ("the IRS") for monies received by them in settlement of a lawsuit against United Airlines ("United"). For the reasons set forth below, plaintiffs' motion will be granted and defendant's motion will be denied...
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