REVISED MEMORANDUM OPINION AND ORDER
QUARLES, District Judge.
Black & Decker Corporation ("B & D") has sued the United States of America for a refund of over $57 million dollars in federal taxes, plus interest, which it contends were erroneously assessed and collected for tax years 1995 through 2000. Pending is B & D's motion for summary judgment on the complaint and the counterclaim. No hearing is necessary. Local Rule 105.6 (D.Md.). For the...
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