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LOVELL v. UNITED STATES

No. 85-8860.

795 F.2d 976 (1986)

Carlos LOVELL, Fred Lovell, Lovell Cattle Co., Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

August 8, 1986.

Attorney(s) appearing for the Case

Robert B. Thompson, Gainesvillle, Ga., James A. Bruton, III and Gerald A. Feffer, Washington, D.C., for plaintiffs-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, William S. Estabrook, Richard J. Driscoll and Roger M. Olsen, Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant-appellee.

Before VANCE and JOHNSON, Circuit Judges, and BOWEN, District Judge.

JOHNSON, Circuit Judge:

This is an appeal from the district court's pretrial order dismissing a suit by appellants for injunctive relief against Internal Revenue Service (IRS) levies and tax liens executed to satisfy a jeopardy assessment. We AFFIRM the judgment of the district court.

I

The IRS entered the jeopardy assessment at issue in this case against Lovana Farms, Inc. ("Lovana"), a Georgia corporation owned by Virgil Lovell. To satisfy a portion...

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