ORDER
FRIOT, District Judge.
This action is brought by taxpayer James W. Cox, d/b/a Cox Machine & Tool, under the Internal Revenue Code, 26 U.S.C. § 6330. That statute is part of the Internal Revenue Service Restructuring and Reform Act of 1998, enacted to provide certain taxpayer protections. See, Mesa Oil, Inc. v. United States, 2000 WL 1745280, *2 (D.Colo.2000) (reviewing legislative history and observing that the Act contains over...
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