McCONNELL, Circuit Judge.
When the estate of Alfred Goldman ("the Estate") filed this tax refund suit in July 2003, it had neither paid the taxes it was disputing nor sought administrative relief before the Internal Revenue Service. The United States accordingly sought dismissal under Rule 12(b)(1) of the Federal Rules of Civil Procedure for lack of subject matter jurisdiction. Rather than suffer dismissal, the Estate paid the taxes, filed a claim before the IRS,...
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