MEMORANDUM DECISION AND ORDER
LODGE, Chief Judge.
PROCEDURAL BACKGROUND
Pending before this court is the Internal Revenue Service's ("IRS") Motion for Summary Judgment. Having fully reviewed the record herein in preparation for the hearing on this motion, the court finds that the facts and legal arguments are adequately presented in the briefs and record. Accordingly, in the interest of avoiding further delay, and because the court conclusively...
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