ROSS, District Judge.
I. Background.
This is an action brought by the United States against defendant to collect certain taxes which plaintiff claims are owing to it. Jurisdiction is predicated on 28 U.S.C. § 1345, which allows the United States to bring suit in federal court regardless of the amount in controversy. Plaintiff alleges that the requirements of 26 U.S.C. § 7401 have been met, in that this action has been directed by the Attorney General...
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