MEMORANDUM OF OPINION AND ORDER
MATIA, District Judge.
This action is before the Court upon plaintiff's Memorandum in Response to Court's Order to Show Cause (Doc. # 14). On January 7, 1993, the Court issued an Order (Doc. # 12) that required that plaintiff show cause why this case should not be dismissed pursuant to Fed.R.Civ.P. 12 for failure to show that this action falls within a statutory or judicial exception to § 7421(a) of the Internal Revenue...
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