OPINION
QUIST, District Judge.
Plaintiff, Coplin and Associates, Inc., is in the business of preparing income tax returns for others. The Internal Revenue Service (IRS) issued a lien on plaintiff's property because of civil penalties against plaintiff for the 1987 and 1988 tax years. The civil penalties against plaintiff are for allegedly violating 26 U.S.C. § 6107(b). This section requires income tax preparers to retain a copy of income tax returns...
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