ORDER
MOLLOY, District Judge.
Background
This is a wrongful levy action under 26 U.S.C. § 7426. Plaintiff Rick Turk ("Rick") is the son of taxpayer Richard Turk ("Richard"). In 1983, Richard Turk was convicted of failing to file an income tax return in the years 1978, 1979, and 1980. He served nine months in prison.
On January 23, 1989, still wrangling with Richard over his late...
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