MEMORANDUM AND ORDER
ATLAS, District Judge.
A bench trial was held before this Court on December 17, 2002, on Plaintiff Morris Weiner's claim for a refund of interest for the tax year 1984 assessed by the IRS pursuant to 226 U.S.C. § 6621(c), the Internal Revenue Code ("IRC") provision authorizing enhanced interest on a substantial underpayment of tax attributable to a tax motivated transaction.
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