MEMORANDUM OPINION AND ORDER
PHILIP PRATT, District Judge.
Plaintiffs are husband and wife who have instituted two actions, one against the Secretary of the Department of Treasury of the United States and the other against the Director of the Department of Social Services of the State of Michigan, challenging the validity of the Internal Revenue Service's transmittal of plaintiffs' 1981 joint tax refund to the State pursuant to the Omnibus Budget Reconciliation...
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