MEMORANDUM DECISION
SCOTT, District Judge.
THIS CAUSE is before the Court upon cross-motions for summary judgment filed by Plaintiffs and Defendant. The question raised by these motions is whether the Plaintiffs are entitled to relief from the effect of the failure to timely file a claim for refund under either the doctrine of equitable recoupment or the mitigation of limitations provisions of the Internal Revenue Code, 26 U.S.C. §§ 1311-1315....
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