MEMORANDUM AND ORDER
CROW, District Judge.
The case comes before the court on defendant's motion to dismiss or, alternatively, for summary judgment. In her original complaint filed June 17, 1985, plaintiff sought to enjoin the Internal Revenue Service (IRS) from enforcing a levy or seeking further levies against her to collect the assessed taxes, penalties and interest for the calendar years 1978 and 1979 due from the estate of Jon M. Haywood. Defendant...
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