MEMORANDUM OPINION
BRIAN BARNETT DUFF, District Judge.
On April 5, 1994, BCS Financial Corp. ("BCS") sued the United States of America ("Government"), seeking to recover a tax refund. On August 22, 1995, the Government moved to dismiss this case, and on November 15, 1995, this Court granted from the bench the Government's motion. On December 7, 1995, BCS moved for reconsideration. BCS' motion has...
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