HENLEY, Chief Judge.
This suit for a refund of federal gift taxes paid by plaintiff, Wilton R. Stephens, with respect to the tax years 1949 and 1956 is now before the Court on the Government's motion to dismiss the complaint as being prematurely filed.
Section 7422(a) of the Internal Revenue Code of 1954 provides that no suit for any refund of an internal revenue tax allegedly assessed or collected erroneously or illegally shall be maintained in any court...
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