Rehearing and Rehearing En Banc Denied June 7, 1988.
BAILEY BROWN, Senior Circuit Judge.
The Canton Police Benevolent Association of Canton, Ohio ("Association") brought this action in the United States District Court for the Northern District of Ohio seeking a refund of $3,367.02 in federal income taxes for the years 1981 through 1984. The Association alleged that the Internal Revenue Service ("IRS") improperly
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