ORDER
WILLIAM D. BROWNING, District Judge.
Pending before the Court are Defendant's April 4, 1994 Motion for Summary Judgment and Plaintiff's May 11, 1994 Motion for Summary Judgment. For the following reasons, the Court will deny Defendant's Motion and grant Plaintiff's Motion.
ORDER AND OPINION
I. Factual and Procedural Background
On September 15, 1987, Plaintiff timely filed a U.S. Corporation Income Tax...
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