MEMORANDUM, OPINION AND ORDER
CONTIE, District Judge.
Plaintiff instituted this action for injunctive relief with the filing of its complaint on August 30, 1978. The Court's jurisdiction is premised upon Section 7402(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 7402(a). Hearing of plaintiff's motion for a preliminary injunction was, pursuant to agreement of the parties, consolidated with the hearing on the merits and held before this Court on...
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