MEMORANDUM OPINION AND ORDER RE: GOVERNMENT'S MOTION TO DISMISS
WANGER, District Judge.
I. INTRODUCTION
On December 4, 1996, Plaintiffs Gilbert Mark Crisp and Rhonda Crisp ("the Crisps") filed a complaint against the government, alleging that the government has no valid lien claims against them based on income tax deficiencies. Now the government moves to dismiss the complaint for lack of subject matter jurisdiction; the Crisps oppose this motion...
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