MEMORANDUM OPINION AND ORDER
TOM S. LEE, District Judge.
Plaintiff Nicholas Acoustics & Specialty Company, Inc. (Nicholas) has brought this action against the United States pursuant to 28 U.S.C. § 1346(a) and 26 U.S.C. § 7422 seeking a refund of overpaid federal employment taxes and abatement of assessed interest and penalties, totaling $263,108.60. The United States has answered, denying that Nicholas has overpaid its federal employment...
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