MEMORANDUM AND ORDER
BUNTON, District Judge.
This is an appeal from the United States Bankruptcy Court for the Western District of Texas, El Paso Division, Thompson, J., denying the debtor's request for injunctive relief against the Internal Revenue Service. Jurisdiction of this court is invoked pursuant to 28 U.S.C. § 1334.
I.
The appellee correctly states the relevant issues for this court's determination as follows:
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