MEMORANDUM-DECISION AND ORDER
LAWRENCE E. KAHN, District Judge.
I. INTRODUCTION
Plaintiff David B. Silipigno commenced this action against the United States on January 7, 2015, to recover tax refunds for the 2004 and 2005 tax years. Dkt. No. 1 ("Complaint") ¶ 1. Plaintiff seeks a refund for the 2004...
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