MEMORANDUM OPINION AND ORDER
WINGATE, District Judge.
INTRODUCTION
This case was heard before the court sitting without a jury on July 19, 1990. The plaintiff, Klingler Electric Company, filed the action against the defendant, the United States of America Internal Revenue Service. Klingler Electric Company (hereinafter referred to as "KEC") seeks a refund of federal income taxes and interest for the taxable years ending October 31, 1981, and October...
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