FINDINGS OF FACT AND CONCLUSIONS OF LAW
LYNN, District Judge.
This case was tried from July 8, 2002— July 16, 2002, and argued on July 25, 2002. Having heard and considered the evidence and the arguments of counsel, the Court makes these Proposed Findings of Fact and Conclusions of Law:
FINDINGS OF FACT
1. This is an action brought under Internal Revenue Code ("Code") sections 6532 and 7422
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