OPINION AND ORDER
GUBOW, District Judge.
Plaintiff Ernest W. White has filed a complaint seeking injunctive relief with respect to the Defendants' jeopardy assessment and levies made pursuant thereto against his property. The court now has before it the Defendants' motion to dismiss the complaint. Arguments and decisions on other motions heretofore filed in the action are being held in abeyance pending a decision on this motion to dismiss.
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