MEMORANDUM OPINION
ROYCE C. LAMBERTH, District Judge.
Plaintiff Siemens USA Holdings, Inc. ("Siemens Holdings"), the parent corporation of a consolidated U.S. tax group of affiliates that includes Siemens Corporation and Siemens Industry, Inc., brings this action for recovery of federal income tax and interest erroneously assessed and collected from it for the tax year ending December 31, 2004. Siemens Holdings
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