MEMORANDUM OPINION
FARNAN, District Judge.
Plaintiffs, Caleb Bailey and Annie Bailey ("Baileys"), filed this action against the United States Government in November of 1985, seeking return of tax refunds that had been seized by the Internal Revenue Service ("IRS"). In their complaint, the Baileys allege that the IRS had improperly retained their 1982 and 1983 tax refunds and they sought the refunds plus interest, costs and attorneys' fees.
The Baileys...
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