MEMORANDUM OPINION AND ORDER
SPORKIN, District Judge.
This matter is before the Court on defendants' motion to dismiss the complaint pursuant to Fed.R.Civ.P. 12(b). Defendants, Lloyd H. Bentsen, Secretary of the Treasury, Margaret M. Richardson, Commissioner of the Internal Revenue Service, and the United States of America, (the "United States"), assert as grounds for dismissal that this Court lacks subject matter jurisdiction over this action. As...
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