MEMORANDUM OPINION
THOMAS H. KINGSMILL, Jr., Bankruptcy Judge.
On August 11, 1989, this matter came before the court as an expedited hearing on Nolan Contracting, Inc.'s ("Debtor") request for a preliminary injunction against the defendant, the United States. The Debtor attempts to enjoin the Internal Revenue Service ("IRS"), an administrative agency of the United States, from assessing the income of Jeffery C. Nolan, who is not a debtor before the court...
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