LAY, Circuit Judge.
Plaintiff Helen Matya brings this appeal from the denial of a preliminary injunction sought against the United States to prevent the Internal Revenue Service from seizing and selling her retail liquor business to satisfy a tax lien filed against herself and her husband, Charles J. Matya, for wagering taxes. The tax lien was based on a jeopardy assessment issued by the government against the plaintiff and her husband in the amount of $793,703.95...
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