MEMORANDUM OF OPINION AND ORDER
NUGENT, District Judge.
Plaintiff, William J. Ross, acting pro se, brings this Complaint seeking a refund of an assessment made against him by the Defendant, United States of America. The Defendant, United States of America filed a Counterclaim against Mr. Ross for the amount owed on the assessment plus statutory interest. On July 8, 1994, the United States of America filed its Motion for Summary Judgment (Doc. # 14...
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