MEMORANDUM AND ORDER
CRONE, United States Magistrate Judge.
Pending before the court is Plaintiff MAXXAM Group, Inc.'s ("MGI") Motion for Partial Summary Judgment (# 5). MGI seeks partial summary judgment against the United States of America on behalf of the Internal Revenue Service ("IRS") on its claim that it appropriately applied single-item treatment to inventory acquired in a stock purchase and its replacement inventory.
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