MEMORANDUM DECISION and ORDER
J. THOMAS GREENE, District Judge.
This matter is before the court on remand from the Tenth Circuit Court of Appeals for entry of judgment in favor of the defendant on its counterclaim. The plaintiff is represented by J. Jay Bullock and Karen Bullock Kreeck of the Bullock Law Firm. The government is represented by Paul M. Warner, U.S. Attorney for the District of Utah and Kirk C. Lusty, attorney for the Tax Division of the Department...
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