Memorandum and Order
CARR, District Judge.
This is a taxpayer's action for a refund of FICA and income withholding assessed by the Internal Revenue Service (IRS) for 1984, 1985 and 1986. The parties have consented to trial and the entry of judgment by the undersigned pursuant to 28 U.S.C. § 636(c). Pending is plaintiff taxpayer's motion for summary judgment. For the reasons set forth below, plaintiff's motion shall be granted.
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