MEMORANDUM OPINION AND ORDER
TUNHEIM, District Judge.
This matter is before the Court on plaintiff Cargill Inc.'s ("Cargill") motion for summary judgment on its tax refund claim of approximately $3,175,506 plus interest for taxable years 1978, 1979, and 1980. The basis for Cargill's claim is that it is the tax owner of an expansion to a grain terminal facility that it leases from the municipal government of the Port of Portland, Oregon. Cargill claims that...
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