OPINION
GOLDBERG, Judge.
This matter comes before the Court on plaintiff's motion for summary judgment. Plaintiff, the United States Customs Service ("Customs"), seeks summary judgment to dismiss a counterclaim filed by Shabahang Persian Carpets, Ltd. ("Shabahang"). The original action, initiated by Customs, involves the recovery of penalties and duties relating to carpets that successfully entered the United States between March 6, 1984 and November...
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