Vaughn v. United States

RULING

SHAW, District Judge.

This matter comes before the Court on the motion of the defendants, the United States of America and the Commissioner of Internal Revenue, to dismiss for failure to state a claim upon which relief can be granted or, alternatively, for summary judgment in their favor. As the disposition of this motion requires resort to materials on file outside of the four corners of the plaintiffs complaint, the Court will consider this motion as one for summary judgment. After a careful review of the materials on file, the Court concludes that there is no genuine issue of material…