MEMORANDUM OPINION AND ORDER
HARDIMAN, District Judge.
I. Introduction
Plaintiffs Sarah and James Cannon brought this action against the United States of America seeking a refund of taxes paid for the 1985, 1988 and 1989 tax years. Pending before the Court are the parties cross-motions for judgment on the pleadings. After careful consideration, the Court will grant the government's motion and deny the Cannons' motion.
II. Standard...
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