MEMORANDUM AND ORDER
ALLEN SHARP, Chief Judge.
This case is before the Court on the defendant's, Internal Revenue Service, motion to dismiss or for summary judgment pursuant to Rules 12 and 56 of the Federal Rules of Civil Procedure. The defendant filed the pending motion on October 21, 1985. A response and motion for summary judgment were filed by the plaintiff, Rachel Templeton, on December 9, 1985. In addition, the defendant filed a motion for a protective...
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