MEMORANDUM & ORDER
HURLEY, District Judge.
INTRODUCTION
Plaintiff Joseph Carione filed suit against the United States, seeking a refund of income tax that he claims to have paid erroneously, and both parties moved for summary judgment. This Court held that the proceeds of Carione's 1998 sale of his business assets, held in escrow and then directly transferred to the Government in 2000 to satisfy an outstanding forfeiture judgment...
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