District Court, D. Kansas November 8, 1994, Civ. A. No. 93-2217-GTV (Monat Capital Corp. v. United States)

MEMORANDUM AND ORDER

BEBBER, District Judge.

I. Introduction

This is a civil tax refund suit brought pursuant to 28 U.S.C. § 1346(a)(1), in which *1514the plaintiff, Monat Capital Corporation (Monat), seeks refund of $1,134,485.78 and $175,-017.91 of federal income taxes and related additions paid for the years 1988 and 1989, respectively.