RULING AND ORDER
BRIAN A. JACKSON, Chief District Judge.
Defendants United States of America and Internal Revenue Service (collectively, "the Government") move to dismiss Plaintiff Kathryn Rothkamm's ("Rothkamm") Complaint for lack of subject-matter jurisdiction pursuant to Federal Rule of Civil Procedure ("Rule") 12(b)(1). (Doc. 3). Rothkamm opposes the Government's motion. (Doc. 4). The Court heard oral argument on the parties' positions...
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