MEMORANDUM OF DECISION AND ORDER
MILTON L. SCHWARTZ, Senior District Judge.
I. Factual and Procedural Background.
Plaintiffs filed this action on August 1, 1990, seeking refund of taxes allegedly illegally and erroneously assessed against plaintiff Jacklyn Tull and collected from both plaintiffs by defendant, acting by and through the Internal Revenue Service ("IRS"). At all relevant times, plaintiff Jacklyn Tull was Secretary and Treasurer...
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