MEMORANDUM OPINION AND ORDER
STAKER, District Judge.
The plaintiff has brought suit pursuant to 26 U.S.C.A. § 7422(a) (West Supp.1988) to recover alleged overpayments of income taxes for the years 1980 and 1981 which resulted from deficiencies being assessed against the plaintiff by the Internal Revenue Service for those years. This court has jurisdiction under 28 U.S.C.A. § 1346(a)(1) (West Supp.1988). The defendant has moved to dismiss the complaint...
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