MEMORANDUM OF DECISION ON PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT
WARREN W. EGINTON, Senior District Judge.
Plaintiff Ambase Corporation ("AmBase") has brought this action seeking a refund of Federal income tax for the tax year 1989. This refund would result from an increased net operating loss ("NOL") deduction carried back to 1989 under 26 U.S.C. § 172 from AmBase's income tax return from 1992. Plaintiff has moved for partial summary...
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