MEMORANDUM AND ORDER DENYING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
GENE CARTER, Chief Judge.
In this litigation, Plaintiffs UNUM Corporation and UNUM Life Insurance Company of America (collectively "UNUM") seek to amend UNUM's 1986 tax return to claim a deduction for an alleged dividend distribution pursuant to UNUM's conversion to a stock company. Now before this Court is the Motion for Summary Judgment filed by Defendant United States of America...
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