MEMORANDUM OPINION AND ORDER
GETZENDANNER, District Judge:
This case is before the court on the defendant's motion to dismiss or in the alternative for summary judgment. The motion is based entirely on the pleadings and therefore shall be treated as a motion for judgment on the pleadings. The allegations of the complaint are taken as true for purposes of this motion.
The plaintiff alleges that he filed his 1982 income tax return which was found to...
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