ORDER
FRANK D. WHITNEY, District Judge.
THIS MATTER is before the Court on the Motion to Dismiss (Doc. No. 4) filed the by the United States of America ("United States"). In the Motion, the United States contends this matter should be dismissed pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure for lack of subject matter jurisdiction and because the Commissioner of the Internal Revenue Service is not a proper party pursuant to Rule 17(a)(1...
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