MEMORANDUM OPINION
BRIAN BARNETT DUFF, District Judge.
On September 7, 1994, Pittway Corp. ("Pittway") sued to recover $410,783 in income taxes, plus interest, that it paid to the government for its taxable year ended December 31, 1984. On January 26, 1995, Pittway moved for summary judgment. On February 9, the government responded to Pittway's motion and moved for judgment on the pleadings. For the reasons discussed below, we deny Pittway's motion...
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