JOSEPH H. YOUNG, District Judge.
The United States of America seeks the return of a tax refund erroneously given to the defendant, Manor Care, Inc. Most of the facts have been stipulated by the parties. On April 11, testimony of one witness was presented by the defendant, and the Court heard argument from the parties. Set forth below are the Court's findings of fact and conclusion of law, in accordance with Rule 52 of the Federal Rules of Civil Procedure.
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