MEMORANDUM OPINION
BATES, District Judge.
Plaintiff seeks damages against the United States pursuant to 26 U.S.C. § 7431(a)(1) based on alleged unlawful disclosures of confidential tax return information by the Internal Revenue Service ("IRS") when it recorded a notice of federal tax lien against plaintiff in the public record. See Compl. ¶¶ 1-13. Defendant has filed a motion to dismiss for lack of subject matter jurisdiction...
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