THORNTON, District Judge.
The Court has before it cross-motions for summary judgment filed by the parties to an income tax refund case. The motion of plaintiffs was filed and heard prior to the filing of the motion by the Government. The Government's motion was accompanied by the filing of a brief. We will consider both motions in this memorandum. Each party to the controversy takes the position that there exists no genuine issue as to any material fact, and that...
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