MEMORANDUM OPINION AND ORDER
CRAIG B. SHAFFER, Magistrate Judge.
This civil action comes before the court on the Internal Revenue Service's ("IRS") "Motion for Summary Judgment" (filed February 1, 2010) (doc. # 45) and the Plaintiffs', Mary M. Hull, Nelson B. Phelps, and the Association of US West Retirees, herein collectively referred to as "Hull", "Motion for Summary Judgment" (filed February 25, 2010) (doc. # 47). Pursuant to 28 U.S.C. § 636(c),...
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