MEMORANDUM OPINION
DOWD, District Judge.
Plaintiff, the United States of America, filed this action against the defendants, Joseph B. Petrelli, et al., on December 23, 1985, seeking a permanent injunction and other equitable relief for the defendants' alleged organization and/or sale of allegedly abusive tax shelters involving artwork plates. On December 24, 1985, this Court held a hearing on the plaintiff's motion for a temporary restraining order...
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