MEMORANDUM OPINION
SPORKIN, District Judge.
At issue in this case is the validity of the defendants' decision that plaintiff must repay $1.2 million in small refiner bias entitlements obtained pursuant to a tripartite crude oil processing arrangement in effect from January through May of 1977. Plaintiff, The Crude Company ("TCC"), challenges the validity of the administrative proceedings held on the issue and of defendants' decision to assess $1.2 million...
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