Memorandum of Decision and Order
MISHLER, Chief Judge.
This is an action for the refund of taxes paid brought pursuant to 26 U.S. C. § 7422. Jurisdiction is alleged to exist under 28 U.S.C. § 1346(a) (1). Defendant has moved for judgment on the pleadings under Rule 12(c) F.R.Civ.P. The essence of defendant's claim is that the court does not have subject matter jurisdiction of the instant controversy in that plaintiff has not filed a timely...
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