ORDER
CARRIGAN, District Judge.
This action arises out of Congress' decision in 1979 to impose an excise or severance tax on the windfall profits expected to result from the gradual decontrol of oil prices in the United States. Plaintiffs Samuel and Nancy Gary commenced this tax refund action to recover a windfall profit tax that they allege was unlawfully withheld. Jurisdiction is alleged to exist pursuant to 26 U.S.C. § 7422 and 28 U.S.C. §&...
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