PER CURIAM.
This three-judge panel has determined unanimously that oral argument would not be of material assistance in the determination of this appeal. See Fed.R.App.P. 34(a); 10th Cir.R. 10(e). The cause is therefore ordered submitted without oral argument.
This is an appeal from an order of the district court granting defendant's motion to dismiss and for summary judgment in plaintiffs' action for refund of taxes brought under 26 U.S.C. § 7422...
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