MEMORANDUM OPINION AND ORDER
BABCOCK, District Judge.
Before me is plaintiff Hoerl & Associates, P.C. (Associates) December 6, 1991 motion for summary judgment on its claim for a partial refund of FICA taxes. The motion has been briefed and submitted on stipulated facts. While defendant United States has not filed a cross motion for summary judgment, it asserts, and Associates does not disagree, that this case can be decided on the stipulated facts and...
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