MEMORANDUM OPINION
JAMES R. SPENCER, District Judge.
THIS MATTER is before the Court on a Motion for Summary Judgment filed by Plaintiffs (ECF No. 5) and a Motion to Dismiss filed by Defendants (ECF No. 30). Plaintiffs move the Court for Summary Judgment alleging that a regulation promulgated by the Internal Revenue Service ("IRS"), which extends eligibility for premium assistance subsidies
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