MEMORANDUM DECISION
ROBERT J. McNICHOLS, Chief Judge.
The plaintiff commenced this action against the United States pursuant to 26 U.S.C. § 7426(b) to enjoin the tax sale of his residence.
Initially the plaintiff sought a Temporary Restraining Order, however, the Government agreed to postpone the sale pending a hearing on an injunction.
An evidentiary hearing was held on November 21, 1984 and November 27, 1984. Post trial memoranda were...
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