Kliens Educational, also known as Kliens Educational & Health Care Services, Inc., Appellant v. Commissioner of Internal Revenue Service, Appellee
Upon consideration of the motion for summary affirmance, the opposition thereto, and the reply, it is
ORDERED that the motion for summary affirmance be denied. The merits of the parties' positions are not so clear as to warrant summary action. See Taxpayers Watchdog, Inc. v. Stanley, 819 F.2d 294, 297 (D.C. Cir. 1987) (per curiam).
Because the court has determined that summary disposition is not in order, the Clerk is directed to enter a briefing schedule.