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THOMSON v. U.S.

Civ. No. 3-93-419.

867 F.Supp. 1420 (1994)

Mary Joyce THOMSON, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Minnesota, Third Division.

August 29, 1994.

Attorney(s) appearing for the Case

Jay Brendan Kelly, Saint Paul, MN, for plaintiff.

John A. Marrella, U.S. Dept. of Justice, Tax Div., Washington, DC, for defendant.

MEMORANDUM OPINION AND ORDER

RENNER, Senior District Judge.

INTRODUCTION

Mary Joyce Thomson brings this action pursuant to 28 U.S.C. § 1346(e) and 26 U.S.C. § 7426 claiming that the Internal Revenue Service ("IRS") wrongfully levied upon certain of her real property.

Both parties subsequently moved for summary judgment on the issue of whether the levy was lawful. The Court1 denied both motions...

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