MEMORANDUM
JOHN T. NIXON, District Judge.
Plaintiffs bring this action pursuant to 28 U.S.C. § 1346(a)(1) for the refund of amounts paid as taxes. The matter is presently before the Court on cross-motions for summary judgment. Defendant's motion will be granted for the reasons discussed below.
On March 22, 1977, the Commissioner of Internal Revenue [hereinafter the Commissioner] forwarded a Notice of Deficiency to Mr. Clark Akers and Ms. Eleanor...
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