MEMORANDUM OPINION
KISER, District Judge.
This is a case arising under the federal income tax laws in which the plaintiff seeks a refund a taxes paid for tax year 1980. The government contends that the plaintiff is barred from a seeking a refund by the doctrine of res judicata. Oral argument on the government's motion for summary judgment was heard on July 29, 1991, and the case is now ripe for disposition. For the reasons set forth below, I agree...
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