MEMORANDUM
JOAN N. FEENEY, Bankruptcy Judge.
The matter before the Court is the United States' Motion for Summary Judgment and the Plaintiff's Opposition to the United States' Motion for Summary Judgment and Cross Motion for Summary Judgment. The Court heard the cross motions on February 6, 2001. The material facts necessary to decide the cross motions are not in dispute. The issues presented are 1) whether the "returns...
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