MEMORANDUM OPINION
BEATY, District Judge.
This matter is before the Court on Defendant's Motion to Dismiss or In The Alternative For Summary Judgment [Document # 6], and Plaintiff's counter Motion for Summary Judgment [Document # 10]. Plaintiff Raymond A. Ingram ("Plaintiff") commenced this action in North Carolina Superior Court after his tax refunds were seized pursuant to 31 U.S.C. § 3720A. The refunds were withheld based on a determination...
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