OPINION
CLARKSON S. FISHER, District Judge.
Before the court is defendant's motion for summary judgment, dismissing plaintiff's action for review of the defendant's determination that plaintiff was not entitled to an income tax credit pursuant to 26 U.S.C. Section 48(g). For the reasons set forth below, defendant's motion is granted.
Plaintiff, the Schneider Partnership, as owner of the Ocean Grove Post Office
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