MEMORANDUM OPINION AND ORDER
KEELEY, District Judge.
This is an action seeking a refund of monies paid to the United States as trust fund recovery penalty taxes. The Court held a bench trial in the matter on October 13, 2004. The parties subsequently filed post-trial memoranda pursuant to the briefing schedule set by the Court. The Court now states its findings of fact and conclusions of law in accordance with Rule 52(a) of the Federal Rules of Civil...
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