MEMORANDUM OF DECISION ON CROSS MOTIONS FOR SUMMARY JUDGMENT [16, 21]
ARTERTON, District Judge.
Plaintiff PARCC Health Care, Inc. ("PARCC") seeks a refund of penalties assessed by the Internal Revenue Service against it for returned checks, failure to timely file quarterly federal employment tax returns and failure to deposit and pay employment taxes withheld from its employees. PARCC and the United States have now cross-moved for summary judgment. While...
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