OPINION ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
HILLMAN, Senior District Judge.
Plaintiffs State of Michigan (the "State") and the Michigan Educational Trust ("MET") brought suit against defendant United States of America (the "government") to compel payment of interest on taxes that the United States Court of Appeals for the Sixth Circuit held to have been erroneously paid by MET. This matter is presently before the court on the parties' cross-motions...
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