MEMORANDUM OPINION
CHARLES R. RICHEY, District Judge.
Plaintiffs, a group of parents with minor children, have brought suit seeking a declaratory judgment with respect to the interpretation and constitutionality of certain provisions of the Tax Reform Act of 1986 (Pub.L. 99-514) (the "Act"). Specifically, plaintiffs challenge Section 1524 of the Act, codified at 26 U.S.C. §§ 6109(e) and 6676(e), which...
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