Girling Health Systems Inc. v. United States

OPINION

YOCK, Judge:

The plaintiff, Girling Health Systems, Inc., seeks money damages and declaratory relief based upon breach of an implied contract with the United States through the Internal Revenue Service. The case is before the Court on the defendant’s motion to dismiss for lack of subject matter jurisdiction.

After oral argument and for the reasons discussed herein, the defendant’s motion is granted, and the plaintiff’s complaint will be dismissed.

Facts

Plaintiff, a “C” corporation, was incorporated on August 1,1982 and has consistently filed its federal income tax returns based on the…