MEMORANDUM OPINION
H. FRANKLIN WATERS, Chief Judge.
Before the court is the motion of the United States to dismiss plaintiffs' cause of action on grounds that the suit was not filed within the two-year period prescribed by the statute of limitations. 26 U.S.C. § 6532. In reply, plaintiffs argue that the United States should be equitably estopped from pleading the statute by virtue of the following facts: (1) That in January, 1983, the Starkeys filed...
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