ORDER GRANTING MOTION TO DISMISS
PHYLLIS J. HAMILTON, District Judge.
Before the court is the motion of respondents Douglas H. Shulman, Commissioner of Internal Revenue, and Internal Revenue Service ("IRS") Revenue Officer David Barbearo, along with real party in interest the United States of America, for an order dismissing the above-entitled action under Federal Rule of Civil Procedure 12(b)(1) for lack of subject matter jurisdiction and under Federal...
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