OPINION and ORDER
ROBERT L. MILLER, Jr., District Judge.
This matter is before the court on a motion to dismiss filed by defendant Marvin D. Miller. Plaintiff United States of America seeks unpaid income tax liabilities and unpaid civil penalty liabilities from Mr. Miller. Pursuant to Federal Rule of Civil Procedure 12(b)(6), Mr. Miller moves to dismiss the complaint for failure to state a claim upon which relief may be granted. He argues the assessment...
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