MEMORANDUM AND ORDER
EARL E. O'CONNOR, District Judge.
This matter is before the court on Defendants' Motion to Dismiss Plaintiffs' Claim for Lack of Subject Matter Jurisdiction (Doc. # 10).
I. Background.
In 1982, Dan Ernzen and his wife Shirley Ernzen purchased farm land from the Frances Ernzen Estate. Their purchase complied with 26 U.S.C. § 2032A (1994), thereby qualifying...
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