MEMORANDUM AND ORDER
STIEHL, District Judge:
Before the Court is plaintiff's motion for summary judgment.
BACKGROUND
On March 8, 1993, defendant submitted amended tax returns claiming refunds of federal income taxes paid for several years, including 1986 and 1987. Defendant's claims for refund were based on claimed entitlement to investment tax credits (hereinafter "ITC"), on the acquisition of personal property with a cost...
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