PER CURIAM:
John R. Montgomery appeals the district court's dismissal of his complaint seeking to quiet title to property seized by the Internal Revenue Service (IRS). We dismiss the appeal as frivolous.
I.
On August 8, 1989, the IRS seized a fifteen-acre tract of land owned by Montgomery to satisfy Montgomery's federal income tax liabilities for 1980 and 1981. On August 14, 1989, the IRS again seized
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