MEMORANDUM OPINION
ROYCE C. LAMBERTH, Chief Judge.
Defendant U.S. Department of Justice, Tax Division ("DOJ", "Tax Division") has filed a Motion to dismiss or in the alternative for summary judgment, pursuant to Federal Rules of Civil Procedure 12(b)(6) and 56(a). Upon consideration of defendant's Motion [49], plaintiff's opposition [56], defendant's reply [59], the applicable law, and the entire record herein, the Court will grant defendant's motion...
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