ORDER
CARRIGAN, District Judge.
Plaintiff William Conway commenced this action against defendant the United States seeking an order declaring an Internal Revenue Service (IRS) assessment under the Internal Revenue Code (Code), 26 U.S.C. §§ 1 et seq., void and unenforceable. Plaintiff also seeks a refund of a sum paid as a divisible portion of that assessment. Defendant has counterclaimed seeking to reduce the assessment to judgment.
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