MEMORANDUM OPINION
JOHN H. PRATT, District Judge.
On February 28, 1980, in a memorandum opinion, we granted defendant's motion for summary judgment, except as to four (4) documents or parts of documents set forth in an order of the same date. On June 8, 1981, the United States Court of Appeals for the District of Columbia Circuit in Shearn Moody, Jr. v. Internal Revenue Service,
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