ORDER ON MOTION FOR INJUNCTIVE RELIEF AND MOTION TO DISMISS
ATKINS, District Judge.
Plaintiff Zion Coptic Church, Inc. (Coptics) seeks to enjoin the defendant Internal Revenue Service (IRS) from selling the sailing vessel "White Cloud". The IRS seized the "White Cloud" pursuant to a jeopardy tax assessment for the 1974-76 years, 26 U.S.C. § 6861(a), and a jeopardy termination assessment for the 1977-78 years, 26 U.S.C. § 6851(a). These jeopardy...
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