MEMORANDUM OPINION
CAHN, District Judge.
The plaintiff, Robert B. Graham, Sr., asks this court to declare unconstitutional and to enjoin the enforcement of the Tax Equity and Fiscal Responsibility Act of 1982, Pub.L. No. 97-248, 96 Stat. 324 ("TEFRA"). All of the defendants have moved to dismiss this action pursuant to Rule 12(b) of the Federal Rules of Civil Procedure. As § 7421(a) of the Internal Revenue...
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