MEMORANDUM OPINION AND ORDER
WALTER S. SMITH, Jr., District Judge.
Came on to be considered the Defendant's Motion for Summary Judgment. The Plaintiff has responded to this Motion, to which the Defendant has replied.
I. Background
This case was originally filed by the Texas Farm Bureau ("TFB") against the United States of America ("USA") seeking a tax refund of $2,126,208.48 for TFB's fiscal years ending October 31, 1984-1987. The...
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