ORDER
PHILIP A. BRIMMER, District Judge.
This matter is before the Court on (1) United States' Motion for Summary Judgment [Docket No. 40] filed by defendant United States Department of the Treasury, Internal Revenue Service ("IRS"); (2) Defendant Rocky Mountain Chiropractic and PremierCare Injury Services Motion for Summary Judgment [Docket No. 41] filed by defendants PremierCare Injury Services, LLC ("PremierCare") and Rocky Mountain Chiropractic Corporation...
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