MEMORANDUM ORDER
FISH, District Judge.
This tax refund suit is before the court on cross-motions for summary judgment. After considering the record in this case, the court is of the opinion that the government's motion for partial summary judgment should be granted in part and denied in part but that the plaintiffs' cross-motion should be denied in its entirety.
I. Legal Standard
Under Rule 56, Fed.R.Civ.P., summary judgment is appropriate...
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