SWYGERT, District Judge.
The defendant resists the motion of the government for summary judgment on counts I, III, and IV of the complaint initially on the ground that the action is prematurely brought. As counsel for the defendant has admitted, this amounts virtually to a petition for a stay of this action pending the disposition of proceedings in the Tax Court for a de novo review of the defendant's renegotiation liability for the taxable years covered by those...
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