ORDER
ADAMS, District Judge.
Before this Court are Defendant's Motion for Summary Judgment (Dkt.32) and Plaintiff's Motion for Partial Summary Judgment as to Liability (Dkt.36). This action is primarily an action for refund of federal income taxes paid by Plaintiff for the years 1982 through 1985. Additionally, Defendant seeks to reopen Plaintiff's tax returns for the years 1976 through 1981 to assess further federal income taxes. This Court, having...
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