MEMORANDUM ORDER
ASPEN, District Judge:
Defendants' motion to dismiss plaintiffs' complaint for lack of subject matter jurisdiction is granted. Plaintiffs assert that jurisdiction in this case is based on 26 U.S.C. §§ 6213(a) and 7421(a) and upon this Court's equitable powers. Section 7421(a) provides that, with limited exceptions, suits to restrain the assessment or collection of any tax may not be maintained in any court by any person...
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