ORDER ON MOTIONS FOR SUMMARY JUDGMENT
JOSE E. MARTINEZ, District Judge.
THIS CAUSE came before the Court upon Plaintiffs Motion for Partial Summary Judgment on Counts II and III with respect to Tax Year 2004 (D.E. No. 45) and the United States's Motion for Partial Summary Judgment (D.E. No. 76). Plaintiff Harold B. Rotte ("Plaintiff") has filed suit against Defendant United States of America ("Defendant"), alleging claims based upon his 1988, 1989...
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