MEMORANDUM
CAFFREY, Senior District Judge.
This is a civil action brought by the United States to recover from the defendant, Brenda A. Reagan, an erroneous refund of Internal Revenue taxes. The United States seeks to recover this money by way of four alternative grounds: erroneous refund, money paid by mistake; money had and received; and conversion. This Court has jurisdiction over the matter pursuant to §§ 7402 and 7405 of the Internal Revenue...
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