MEMORANDUM AND ORDER
PATEL, Chief Judge.
On December 20, 1996, Plaintiff Lori Barber filed this action seeking a refund of income tax that she alleges was erroneously and illegally assessed and collected. This court has jurisdiction pursuant to 28 U.S.C. section 1346(a)(1). Now before the court are plaintiff's and defendant's cross motions for summary judgment.
BACKGROUND
Lori Barber was a licensed real estate salesperson in 1988...
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