DECISION AND ENTRY SUSTAINING IN PART AND OVERRULING IN PART PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT (DOC. # 23); PLAINTIFF MAY RENEW MOTION, AS TO ALL COUNTS SET FORTH IN THE COMPLAINT (DOC. # 1), WITHIN 60 DAYS FROM DATE
RICE, Chief Judge.
In this action, in its first count, Plaintiff United States of America ("Government") seeks to reduce three Internal Revenue
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