ORDER REGARDING MOTION FOR PARTIAL SUMMARY JUDGMENT
SHERMAN G. FINESILVER, Chief Judge.
This is a case involving an alleged overpayment of taxes. This matter comes before the Court on Defendant's motion for partial summary judgment. Jurisdiction is based on 28 U.S.C.A. § 1331. The litigants have fully briefed the matter. For the reasons stated below, the motion is DENIED.
I.
Plaintiff Larry J. Engelken is a general partner of Plaintiff...
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