OPINION OF THE COURT
SEITZ, Circuit Judge.
The plaintiff, Rolling Rock Club, appeals the denial of its motion for summary judgment and the grant of summary judgment to the government in this action under 26 U.S.C. § 7422 (1982) for a refund of $329,918.57 plus interest paid for taxes and interest after the Internal Revenue Service disallowed dividends received deductions claimed for the tax years 1974 and 1975. We have jurisdiction under 28 U.S.C. ...
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