ON DEFENDANT'S MOTION AND PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT
COWEN, Chief Judge:
Plaintiff, Peninsula Motor Club (Peninsula), brings this action for the recovery of income taxes and accompanying interest paid for the taxable year ended December 31, 1968. Upon audit by the Internal Revenue Service, plaintiff's income for its 1970 and 1971 taxable years was increased and its net operating losses for those...
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