COURT'S FINDINGS OF FACTS AND CONCLUSIONS OF LAW
DOWNES, District Judge.
The above-captioned matter came before the Court for a non-jury trial. Plaintiff appeared and was represented by Denis H. Mark and William C. Waller, Jr. and Defendant was represented by R. Scott Clarke and Stuart Gibson, Department of Justice, Tax Division. The Court, having heard the evidence of both parties, having reviewed the pleadings and otherwise being fully advised in the premises...
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