MEMORANDUM OPINION
BULLOCK, District Judge.
Plaintiff and Counterclaim Defendant Alfred Abdo, Jr. ("Abdo"), a tax return preparer, filed this action pro se on January 24, 2001, seeking declaratory and injunctive relief on behalf of his clients in order to obtain refunds allegedly owed them from the Internal Revenue Service ("IRS"). The IRS filed a motion to dismiss on March 29, 2001, and an answer and counterclaim on May 15, 2001, seeking to...
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