OPINION AND ORDER
MARSH, District Judge.
Plaintiffs Crowd Management, Inc. ("CMS") and James J. DeLoretto ("DeLoretto") brought this action seeking a refund from the Internal Revenue Service (the "IRS") of payments made to the IRS for assessments and penalties arising from plaintiffs' classification of workers as independent contractors rather than employees for employment tax purposes. Plaintiff DeLoretto also brought claims for damages against defendant...
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