MEMORANDUM OPINION
CHURCHILL, District Judge.
The Internal Revenue Service (IRS) filed a motion for summary judgment in this Freedom of Information Act (FOIA) case. The plaintiffs filed a response in which they also seek summary judgment in their favor. The IRS filed a response to the cross-motion and the plaintiffs replied. Oral argument was heard on August 22, 1994.
The plaintiffs have been involved in a tax dispute with the IRS. In response...
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