OPINION OF THE COURT
SEITZ, Chief Judge.
This appeal raises the issue of whether a taxpayer whose property has been seized and sold by the federal government for non-payment of federal taxes may thereafter bring suit against the United States to quiet title to that same property provided that he refrains from contesting the merits of the underlying tax assessment itself.
Plaintiff, Aqua Bar & Lounge, Inc. ("plaintiff") was the owner of a restaurant...
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