KENNEDY, Circuit Judge.
Defendant appeals the order of the District Court granting summary judgment in favor of plaintiff United States in this action to recover an erroneous tax refund. The District Court entered a judgment against the defendant in the amount of $276,079.99 plus statutory interest. Defendant argues on appeal that the District Court erred in granting summary judgment to plaintiff because plaintiff should be equitably estopped from recovering the erroneous...
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