ORDER
VINSON, District Judge.
Pending are cross-motions for summary judgment. (Docs. 56, 57).
I. BACKGROUND
The pro se plaintiff, Wilford Simpson, filed this action to quiet title to certain personal property on which the defendant, the United States of America, claims an income tax lien. Simpson does not dispute the merits of the underlying assessment, but only the procedures used by the government in imposing the liens and levies.
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