PLAGER, Circuit Judge.
In substance this case is one for the recovery by the Internal Revenue Service ("IRS" or "Government") of a large refund paid in error to a taxpayer. In form, however, the taxpayer is seeking money from the Government, having remitted to the IRS an amount similar to the refund, demanded by the IRS in connection with a different, once-disputed but subsequently satisfied income tax liability. The Government claims the right to retain the sum the...
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