ORDER
G. ERNEST TIDWELL, District Judge.
The above-styled motion is before the court on cross-motions for summary judgment.
In this proceeding, plaintiff, RJR Nabisco, Inc. ("RJR"), seeks to recover a portion of the interest payment it paid to the defendant, the Internal Revenue Service ("IRS"), on a tax deficiency and penalty. All of the facts have been stipulated to and both parties have filed motions for summary judgment.
On August 22...
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