MEMORANDUM OPINION AND ORDER
SHADUR, District Judge.
Raymond Wells ("Wells") has sued for a permanent injunction against the United States and its agents, including the Internal Revenue Service ("IRS"), to enjoin the assessment and collection of certain withholding taxes assessed against Wells. In response the United States has filed a Fed. R.Civ.P. ("Rule") 12(b)(6) motion to dismiss the Complaint as barred by 26 U.S.C. § 7421(a)
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