ORDER
SHUBB, District Judge.
This tax refund suit is before the Court on cross-motions for summary judgment under Fed.R.Civ.P. 56.
On May 14, 1979, the IRS discovered an error in plaintiffs' timely-filed tax return for the 1978 tax year. The IRS adjusted plaintiffs' tax owing (line 35 of the return) from $4,388.00 to $11,500.32 and erroneously allowed plaintiffs credits of $11,614.00, refunding to plaintiffs $113.68. On April 19, 1982, the IRS reversed...
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