MEMORANDUM DECISION
CONWAY, District Judge.
I. INTRODUCTION
This case was tried before the Court, without a jury, on June 5 and 6, 1995. Upon consideration of the parties' evidence, arguments and legal memoranda, the Court issues this memorandum decision.
II. PROCEDURAL BACKGROUND
The plaintiff, James B. Curasi, commenced this action "to recover an unstated amount of taxes paid in partial satisfaction of assessments...
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