MEMORANDUM
RAMBO, District Judge.
Before the court is defendant's Rule 12 motion to dismiss for lack of subject matter jurisdiction or, in the alternative, for failure to state a claim upon which relief can be granted. The motion has been fully briefed and is ripe for disposition.
On July 7, 1987 the Internal Revenue Service notified plaintiff by letter that there was a deficiency in plaintiff's income tax for the years 1982 through 1985. The notice...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.
