MEMORANDUM OPINION
FARNAN, Chief Judge.
Presently before the Court are cross-motions for summary judgment filed by the parties in this civil action for a tax refund. Plaintiffs Joseph S. Rodek and Marion N. Rodek ("Plaintiffs") filed suit against the United States of America (the "Government") pursuant to 28 U.S.C. § 1346(a), seeking recovery of internal revenue taxes, which they allege were erroneously and illegally assessed against them and...
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