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ALON INTERN., INC. v. U.S.

Civ. A. No. 94-1801.

910 F.Supp. 233 (1995)

ALON INTERNATIONAL, INC., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Pennsylvania.

September 5, 1995.

Attorney(s) appearing for the Case

David J. Kalson, Cohen & Grigsby, Pittsburgh, PA, for plaintiff.

Michelle O. Gutzmer, United States Attorney's Office, Pittsburgh, PA, Charles M. Flesch, and Gerard J. Mene, U.S. Department of Justice, Tax Division, Washington, DC, for defendant.

MEMORANDUM OPINION

LEE, District Judge.

Before the Court are Defendant's Motion for Summary Judgment (Document No. 7) and Plaintiff's Cross-Motion for Summary Judgment (Document No. 12). For the reasons stated below, Plaintiff's motion for summary judgment will be denied and Defendant's motion for summary judgment will be granted.

I. FACTUAL BACKGROUND

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