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F.P.P. ENTERPRISES v. UNITED STATES

No. CV. 84-0-570.

646 F.Supp. 713 (1986)

F.P.P. ENTERPRISES, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Nebraska.

September 10, 1986.

Attorney(s) appearing for the Case

Arthur P. Tranakos, Atlanta, Ga., for plaintiffs.

Janice Teague, Tax Div., Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION

STROM, District Judge.

This matter is before the Court for determination after trial on August 19, 1986. The parties have presented their evidence and briefs supporting their respective positions, and this case is now ready for decision.

I. BACKGROUND

In this action, the named plaintiffs, F.P.P. Enterprises and D & S Trust seek a permanent injunction enjoining the defendant from further actions of levy and restraint...

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