MEMORANDUM OPINION AND ORDER
ANNA DIGGS TAYLOR, District Judge.
This Memorandum Opinion constitutes the findings of fact and conclusions of law of the Court, after trial to the bench. Plaintiff, Ames Investment, brought this lawsuit against Defendants, the Internal Revenue Service ("IRS") and IRS Revenue Officer Michael E. Rogala, alleging that the Defendants wrongfully seized Plaintiff's real property to satisfy the tax debt of one of its shareholders...
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