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NETWORK SYSTEMS CORP. v. U.S.

No. 4-91-CV-869.

814 F.Supp. 778 (1993)

NETWORK SYSTEMS CORPORATION v. UNITED STATES of America.

United States District Court, D. of Minn., Fourth Division.

February 18, 1993.

Attorney(s) appearing for the Case

Clinton A. Schroeder, Myron L. Frans, Gray Plant Mooty Mooty & Bennett, Minneapolis, MN, Gregory A. Markel, John Houston Pope, Davis Markel & Edwards, New York City, Malcolm D. Reid, Minneapolis, MN, for plaintiff.

Robert Michael Small, Asst. U.S. Atty., Minneapolis, MN, S. Hollis Fleischer, U.S. Dept. of Justice, Tax Div., Rachel D. Cramer, U.S. Dept. of Justice, Tax Division, Washington, DC, for defendant.

ORDER

ROSENBAUM, District Judge.

Plaintiff seeks judgment on the pleadings on Counts I, II, and III of its complaint, pursuant to Rule 12(c), Federal Rules of Civil Procedure (Fed.R.Civ.P.). Plaintiff asks for return of certain taxes, interest, and penalties paid, under protest, for tax years 1983, 1984, and 1985. The Court heard argument on October 30, 1992. Plaintiff has presented, and the Court has considered, matters outside the pleadings. Therefore...

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