OPINION AND ORDER REGARDING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
ROSEN, District Judge.
I. INTRODUCTION
Plaintiffs Robert and Janice Fisher, husband and wife, filed this action on July 2, 1997 to recover federal income tax and interest which they claim was erroneously and illegally assessed and collected by the Internal Revenue Service for the years 1985 through 1996. This matter is presently before the Court on the Government...
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