MEMORANDUM OPINION
JOHNSTONE, Chief Judge.
This action was brought by Leora A. Yoak, as trustee of the Robert W. Yoak Equity Trust, to temporarily and permanently enjoin the Commissioner of the Internal Revenue Service from wrongfully seizing property of the trust. Robert W. Yoak has moved to intervene as a plaintiff in this action, and the United States has filed a Counterclaim against Robert W. and Leora A. Yoak. In the Counterclaim the United States seeks...
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