MEMORANDUM OPINION AND ORDER
KANE, District Judge.
This case comes before me on the motion of the United States to dismiss pursuant to Rule 37(b) F.R.C.P. The plaintiff, a certified public accountant, has filed the fourteen above numbered cases against the United States. All of these cases allege that 26 U.S.C. § 6694 is facially unconstitutional. Each case is based upon the preparation of a taxpayer's return in which the plaintiff, as preparer, excluded...
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