OPINION AND ORDER
ELLIOTT, District Judge.
The Plaintiffs above named filed this action on April 21, 1988, seeking to enjoin the United States from taking any collection activity against the Plaintiffs with respect to the tax liabilities of Andrew M. and Margaret Dixon (taxpayers) and to order the return of any of Plaintiffs' property which the Defendant had levied upon for satisfaction of the taxpayers' liabilities, jurisdiction being claimed under 26 U...
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