ORDER
PHILIP A. BRIMMER, District Judge.
This matter is before the Court on the Motion to Dismiss [Docket No. 19] filed by defendants Leslie A. Powers and Powers and Therrien, P.S. ("P&T"). The Court has subject matter jurisdiction over this case pursuant to 28 U.S.C. § 1332.
I. BACKGROUND
This case arises out of defendants Alan DeAtley and Richard Davis' sale of income tax credits for conservation easements. In Colorado, a taxpayer...
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