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INVESTORS SYNDICATE OF AMERICA, INC. v. SIMON

Civ. A. No. 75-1984.

407 F.Supp. 83 (1975)

INVESTORS SYNDICATE OF AMERICA, INC., Plaintiff, v. William E. SIMON, Secretary of the Treasury, and Donald C. Alexander, Commissioner of Internal Revenue, Defendants.

United States District Court, District of Columbia.

December 29, 1975.

Attorney(s) appearing for the Case

David W. Richmond, Robert L. Moore, II, Washington, D. C., for plaintiff.

Donald J. Gavin, John M. Cunningham, U. S. Dept. of Justice, Washington, D. C., for defendants.

MEMORANDUM OPINION

BRYANT, District Judge.

This case is before the Court on plaintiff's Motion For Preliminary Injunction and defendants' Motion To Dismiss. In this action plaintiff seeks to have the Court enjoin the January 1, 1976 implementation of Treasury Regulations § 1.1232-1(c)(3) and § 1.1232-3A(f)(1), while the government asks that the action be dismissed for an asserted lack of proper subject matter jurisdiction, pursuant to F.R.C.P....

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