ORDER
SANDS, District Judge.
The Government filed this action to recover damages for an unpaid tax liability due on the Estate of Willie G. Holt. The gravamen of the Government's complaint is that the defendants named herein are allegedly liable for the unpaid tax of the estate under Georgia law because they are beneficiaries of the estate. The Court has jurisdiction over this action, pursuant to 28 U.S.C. § 1345.
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