Liberty Mutual Insurance v. United States

ORDER

LINDSAY, District Judge.

ADOPTED by Lindsay, D.J. on January 23, 2008.

CONSOLIDATED REPORT AND RECOMMENDATION ON PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT (Docket #21) and UNITED STATES’ MOTION FOR SUMMARY JUDGMENT (Docket #31) and ORDER ON PLAINTIFFS’ MOTION TO COMPEL (Docket # 27)

ALEXANDER, United States Magistrate Judge.

At its base, this is a federal tax refund case. As the parties agreed during oral argument, however, this also happens to be a federal tax refund case of, essentially, first impression for the courts. 1 Both Liberty Mutual and the United States move for summary judgment…