MEMORANDUM OPINION AND ORDER
BABCOCK, District Judge.
The United States of America (the government) moves to dismiss this case for lack of subject matter jurisdiction pursuant to Fed. R.Civ.P. 12(b)(1). The motion is inadequately briefed but oral argument would only confuse its resolution. For the reasons set forth below, which state a case for a simple tax code, I grant the government's motion to dismiss.
I. FACTS
The record reflects the...
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