PER CURIAM.
Plaintiff Miller appeals the District Court's grant of defendant's motion to dismiss for lack of subject matter jurisdiction. The District Court held that because the filing of a refund claim is a jurisdictional prerequisite to a tax refund action, 26 U.S.C. § 7422(a) (Internal Revenue Code of 1954, "the Code"), and since plaintiff's claim for refund was not timely filed, the court had no jurisdiction to entertain the suit.
The Internal Revenue...
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