MEMORANDUM OPINION
KATZ, District Judge.
Pending before this Court are cross-motions for summary judgment in the above-captioned matter. Jurisdiction is proper in this Court pursuant to 28 U.S.C. § 1346(a)(1) and 26 U.S.C. § 7422. Based upon careful consideration of the parties' motions, oppositions and replies, and the entire record herein, the Court will grant in part and deny in part Defendant's motion. The Court will deny Plaintiff's...
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