DECISION and ORDER
THOMAS J. McAVOY, Senior District Judge.
The United States of America commenced the instant action seeking to enjoin Defendants from promoting an illegal tax shelter. Presently before the Court are Defendants' motion to dismiss pursuant to Fed.R.Civ.P. 12 and Plaintiffs cross-motion for summary judgment pursuant to Fed.R.Civ.P. 56.
Defendant Robert L. Shulz ("Schulz") organized Defendant We...
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