OPINION
ALLEY, District Judge.
Before the Court are Cross Motions for Summary Judgment filed by plaintiffs and defendant. The parties have filed a Joint Stipulation of Facts, set forth below. Because the parties herein have determined that no issues of material fact are in dispute, imposition of summary judgment on the legal issue presented is appropriate. See Fed. R.Civ.P. 56. At issue is whether the portions of net operating losses incurred...
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