MEMORANDUM OPINION AND ORDER
LEWIS, District Judge.
The facts in this case are not in dispute —On March 17, 1971, one Lee G. Snellings had an installment loan account with Peoples Bank of Stafford secured by a 1971 Ford automobile, together with his authorization for the bank to charge the installments when and as due to his checking account in the bank.
On September 3rd an appropriate official of Internal Revenue Service assessed Snellings...
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