OPINION AND ORDER
FEIKENS, District Judge.
Plaintiffs Cesar and Mona Sy filed suit to recover money paid to the United States Internal Revenue Service (IRS), and now move for summary judgment. The IRS has moved to dismiss the complaint for failure to state a claim, Fed.R.Civ.P.. 12(b)(6), and, in the alternative, cross-moved for summary judgment. For the reasons stated below, summary judgment is granted for the IRS.
I. Background...
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