ORDER
SHEDD, District Judge.
This case is before the Court for disposition pursuant to Federal Rule of Civil Procedure 56 as to Plaintiff's Cross Motion for Summary Judgment filed May 29, 1998. This Court, also on May 29, 1998, Ordered, sua sponte, the Government to file a responsive brief setting forth its arguments opposing summary judgment based on the "safe haven" provisions of Section 530 of the Revenue Act of 1978, 26 U.S.C. § 3401...
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