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IOWA 80 GROUP, INC. & SUBSIDIARIES v. U.S.

No. 3:00-CV-90217.

203 F.Supp.2d 1058 (2002)

IOWA 80 GROUP, INC. & SUBSIDIARIES (Formerly Iowa 80 Truckstop, Inc. and Subsidiaries), Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, S.D. Iowa, Davenport Division.

May 23, 2002.

Attorney(s) appearing for the Case

Gene H. Snapp, Jr., John S. Gosma, Davenport, IA, for Plaintiff.

Joan Stentiford Ulmer, Tax Division, U.S. Department of Justice, Washington, DC, for Defendant.

MEMORANDUM OPINION AND ORDER

PRATT, District Judge.

The Plaintiff, Iowa 80 Group, Inc. ("Iowa 80") brought this action against the United States for a taxpayer refund pursuant to 26 U.S.C. § 7422. The United States now moves for summary judgment and for the foregoing reasons, the motion is granted in part and denied in part.

I. Factual Background

Through its subsidiaries, Iowa 80 owns...

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