MEMORANDUM OPINION
DAWSON, District Judge.
This taxpayer refund action is before the court on the defendant's motion for partial summary judgment. Specifically, the United States has moved for summary judgment on the issue of whether plaintiff's purchase of new trucks, and sales of used trucks, constitute purchase and sale transactions on which a gain or loss should be recognized rather than non-taxable exchanges of like-kind property under 26 U.S...
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