Berridge v. United States

OPINION AND ORDER

GEORGE C. SMITH, District Judge.

This matter is before the Court pursuant of the Defendant, United States of America’s, Motion for Dismissal under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). The government has moved for the dismissal of this action for lack of jurisdiction and failure to state a claim upon which relief can be granted. Jurisdiction in this matter is alleged under Title 28 U.S.C. § 1331.

FACTS

For purposes of the instant motions the relevant alleged facts are fairly simple. The plaintiffs essentially allege that the Internal Revenue Service (“IRS”), a…