MEMORANDUM OPINION AND ORDER
WOODWARD, Senior District Judge.
Pending before the Court are cross-motions for summary judgment. The Court has considered said motions, together with Stipulations of Fact, briefs, supporting materials, and oral argument of counsel.
The parties have submitted a Joint Stipulation of Facts which the Court incorporates herein by reference. The issue presented is what statute of limitations applies when the Internal Revenue...
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