MEMORANDUM OPINION AND ORDER
KANE, District Judge.
This motion to dismiss alleges that subject matter jurisdiction over the pertinent issues is lacking, that express statutory procedural limitations prohibit the exercise of this court's jurisdiction, and that declaratory and injunctive relief are proscribed in federal tax actions.
Two other parties petitioned to intervene in this action pursuant to F.R.Civ.P. 24, and those motions were granted. It...
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