DECISION AND ORDER
LAGUEUX, Chief Judge.
This matter is before the Court on motions filed by both defendants to dismiss the Complaint pursuant to Fed.R.Civ.P. 12(b)(6). Defendants, Federal Deposit Insurance Corporation ("FDIC") and Allan M. Shine ("Shine"), seek to dismiss the claims brought by the United States on behalf of the Internal Revenue Service ("IRS") to recover a capital gains tax generated by the sale of corporate property in a state court...
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