MEMORANDUM OPINION AND ORDER
JOINER, District Judge.
This is an action under 26 U.S.C. § 7426 brought by plaintiff for wrongful levy by the Internal Revenue Service (IRS) upon funds which the plaintiff alleges were rightfully his. The defendant has moved to dismiss the complaint for lack of jurisdiction. The following facts appear from the pleadings, exhibits, and a supplemental affidavit filed by the government.
On December 16, 1971, IRS served...
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