MEMORANDUM OPINION
BEATY, District Judge.
This matter is before the Court on Plaintiff and Defendant's Motions for Summary Judgment.
I. FACTUAL BACKGROUND
This is an action for a tax refund of $17,730,600 based upon an alleged "greenmail" payment made in connection with the purchase of common stock. Plaintiff, Wrangler Apparel Corp., merged with Blue Bell, Inc. ("Blue Bell") and has assumed Blue Bell's tax refund claim, though the events...
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