OPINION
DAUGHERTY, District Judge.
Plaintiffs bring this suit to enjoin the Internal Revenue Service agents of the United States (IRS) to refrain from further efforts to assess and collect income tax which the IRS claims is due from Plaintiff John P. Needham for the year 1970. This action was tried to the Court on April 26, 1982, and, having consulted the authorities cited by the parties in their trial briefs and their respective Proposed Findings of Fact...
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