OPINION AND ORDER
ROBERT E. JONES, District Judge:
Plaintiffs Kenneth and Anita Rossi bring this action to challenge the seizure and sale of plaintiffs' land by the Internal Revenue Service (IRS) to satisfy income tax indebtedness. Plaintiffs challenge the procedural regularity of the tax assessment and the notice of tax liability and demand for payment, or alleged lack of, by the IRS prior to the seizure and sale of plaintiffs' land. Plaintiffs also claim...
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