MEMORANDUM OPINION AND ORDER
ROBERT M. HILL, District Judge.
Came on for consideration before the Court a civil action for a refund of federal income taxes paid by plaintiff, Silco, Inc. (Silco). The case has been submitted for determination on stipulated facts. Jurisdiction is proper under 28 U.S.C. § 1346(a)(1). Having considered the parties' briefs and the relevant case law, as well as having heard oral argument of counsel, the Court is of the opinion...
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