MEMORANDUM OPINION
JOHN D. BATES, District Judge.
On November 27, 2006, the Court held that plaintiffs failed to exhaust administrative remedies as required by 26 U.S.C. § 7433(d) and 26 C.F.R. § 301.7433-1(e) and therefore dismissed this action for failure to state a claim upon which relief can be granted pursuant to Fed.R.Civ.P. 12(b)(6). See Mem. Op. at 2006 WL 3408188, at *7-10. The Court also dismissed for lack of subject matter...
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