ORDER
TIDWELL, District Judge.
This case came on for trial before the court on February 22, 1982. After considering all of the evidence as well as memoranda submitted by counsel subsequent to the trial, the court enters the following findings of fact and conclusions of law:
FINDINGS OF FACT
1. This is a civil action brought by the United States, authorized and requested by the chief counsel of the Internal Revenue Service, to reduce federal...
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