ORDER
BERMAN, District Judge.
Plaintiff, the United States of America ("Plaintiff" or the "IRS" or the "Government"), filed this action on or about December 10, 1997 to recover a $1,526,100.60 interest payment it erroneously made to defendant, Tate & Lyle North American Sugars, Inc. ("Defendant" or "Tate & Lyle,")
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