WIDENER, Circuit Judge:
This is an appeal of an order of the district court dismissing a complaint filed by a taxpayer seeking to prevent the government from enforcing a federal tax lien against the taxpayer's property. The government filed a motion to dismiss the complaint under FRCP 12(b)(1) for lack of jurisdiction and, alternatively, under FRCP 12(b)(6) for failure to state a claim upon which relief could be granted. Without specifying which FRCP 12(b) provision...
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