MEMORANDUM
COLLIER, District Judge.
Plaintiff Provident Life and Accident Insurance Company ("Provident Life") brought this action pursuant to 26 U.S.C. § 7422(a) to recover federal income taxes and related interest collected from Provident Life for the tax year 1984 (Court File No. 1, Complaint). This Court has subject matter jurisdiction over this case pursuant to 28 U.S.C. § 1346(a)(1), and venue is proper in this district pursuant to...
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