RULING ON MOTION FOR SUMMARY JUDGMENT
CHARLES S. HAIGHT, JR., Senior District Judge.
I. INTRODUCTION AND RELEVANT FACTS
Plaintiffs Emerging Money Corporation (EMC), Emerging Administrative Services, LLC and Emerging Actuarial Designs, LLC allege that the Internal Revenue Service (IRS) wrongfully disclosed information when it asserted to certain taxpayers that the transactions that Plaintiffs had promoted to them were "sham transactions"...
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