MEMORANDUM AND ORDER RE: MOTION TO DISMISS
WILLIAM B. SHUBB, District Judge.
Plaintiffs Alan and Wendy Pesky brought suit against the United States of America seeking a refund for taxes, penalties, and interest assessed against them for the 2003 and 2004 tax years. After a stay of the action and the filing of the First Amended Complaint, the United States filed counterclaims against the Peskys. The Peskys now seek to dismiss the United States' counterclaims...
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