OPINION AND ORDER
PATRICIA CAMPBELL-SMITH, Chief Judge.
Plaintiffs Jeffrey and Kim Greiner seek a refund of $4,742,703 in federal income taxes for the 2008 and 2009 tax years, plus interest and costs. Compl. ¶¶ 30, 34, ECF No. 1. This court's jurisdiction over their refund suit is not in dispute,
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