FINDINGS OF FACT AND CONCLUSIONS OF LAW
BERMAN, District Judge.
I. Introduction
On or about December 10, 1997, plaintiff the United States of America ("Plaintiff" or the "IRS" or the "Government") commenced this action, "seek[ing] to recover a $1,526,100.60 interest payment it made to defendant Tate & Lyle North American Sugars, Inc., successor to Domino Sugar Corporation, formerly known as Amstar Sugar Corporation ..., when the [IRS...
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