ORDER RULING ON MOTIONS FOR SUMMARY JUDGMENT WITH FINDINGS
KERR, District Judge.
The above-entitled matter coming on regularly for hearing before the Court on defendants Sterners' motion for summary judgment and plaintiff's cross-motion for summary judgment; plaintiff appearing by and through its attorney, John D. Steffan, Trial Attorney, Tax Division, United States Department of Justice, and defendants Sterners appearing by and through their attorney, Susan...
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