SHERIDAN, Chief Judge.
The United States of America has moved to dismiss plaintiff's complaint for a preliminary injunction.
Plaintiff seeks to enjoin the defendant from levying on his assets until plaintiff's claim for a refund has been determined. On September 18, 1972, plaintiff was assessed a 100% penalty of $8,330.39 for the alleged willful failure to remit income and FICA withholding taxes from employees of Wilkay, Inc....
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