MEMORANDUM OF DECISION
DAVID E. RUSSELL, Chief Judge.
This matter comes before the court on defendant Gerald Goldberg's ("Goldberg") Motion to Dismiss the adversary proceeding for lack of jurisdiction. Debtor James Ellett ("Debtor") filed this adversary proceeding on November 13, 1997 against Goldberg, the Executive Director of the California Franchise Tax Board ("FTB"), seeking a declaration that his state income tax liabilities for certain years between...
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