MEMORANDUM
EDGAR, District Judge.
This matter is presently before the Court on defendant's motion for reconsideration of the Court's order of August 21, 1985, denying in part the defendant's motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6). The Court, on September 17, 1985, ordered the parties to prepare briefs addressing the issues of whether it is an abuse of discretion on the part of the Commissioner of the Internal Revenue to accept...
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