MEMORANDUM OPINION AND ORDER
RICHARD H. KYLE, District Judge.
INTRODUCTION
This action arises out of the IRS's erroneous refund of nearly $600,000 to Fred H. Bame in 2005, a portion of which was transferred to Bame's wife, Defendant JoAnna Bame, and two of her companies, Defendants I Am Home, Inc. ("I Am Home") and Hook 'n Horn Ltd. ("Hook 'n Horn").
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