WEBB v. U.S.

Civ. A. No. 3:93CV847.

850 F.Supp. 489 (1994)

Clinton WEBB, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Virginia, Richmond Division.

May 4, 1994.


Attorney(s) appearing for the Case

John Codd Irvins, Jr., Brian Keith Jackson, Everette G. Allen, Jr., Charles Frederick Witthoefft, Hirschler, Fleischer, Weinberg, Cox & Allen, Richmond, VA, for plaintiffs.

Debra J. Prillaman, Asst. U.S. Atty., Richmond, VA, and Gerard Mene, Dept. of Justice, Tax Div., Washington, DC, for defendant.


MEMORANDUM OPINION

RICHARD L. WILLIAMS, Senior District Judge.

This matter is before the Court on defendant's motion to dismiss, pursuant to Fed. R.Civ.P. 12(b)(1) and 12(b)(6), for lack of subject matter jurisdiction and for failure to state a claim on which relief can be granted. For the reasons set forth below, the Court grants the motion pursuant to Fed.R.Civ.P. 12(b)(1).

I. Facts

On April 5, 1988, Mary Morton Parsons...

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