JENKINS, District Judge.
This is an action for an income tax refund. The matter came on for hearing before the court on Cross-Motions for Summary Judgment. Plaintiffs were represented by Dan Bushnell and Robert Lunt. Defendant was represented by Robert Horowitz. The court heard oral argument and took the matter under advisement. Upon reviewing the memoranda submitted, governing legal authority, and the arguments made at hearing, the court renders the following memorandum...
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