ORDER
DONALD E. O'BRIEN, Chief Judge.
The underlying action was instituted by the plaintiff to recover funds remitted to the Internal Revenue Service ("IRS"). The defendant has moved to dismiss plaintiff's action on the grounds that (1) the statute of limitations has expired and (2) the plaintiff failed to comply with the requirements necessary to waive the sovereign immunity of the United States. The Court, having considered the materials on file, the arguments...
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