MEMORANDUM AND ORDER
CRONE, United States Magistrate Judge.
I. Introduction
Pending before the court is Defendant United States of America's ("United States") Motion to Dismiss or for Summary Judgment (# 12). The United States, on behalf of the Commissioner of the Internal Revenue Service ("IRS"), seeks summary judgment on the complaint of Plaintiff Naman Abu-Awad ("Awad"), doing business as Stat Physical Therapy ("Stat"), challenging a...
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