OPINION
ENSLEN, District Judge.
This case is before the Court on defendant's motion to dismiss, or, in the alternative, motion for summary judgment, filed May 21, 1990. Plaintiff filed a complaint on March 8, 1990 seeking to quiet title, pursuant to 28 U.S.C. § 2410 (1988), to property allegedly subject to a federal government lien of the Internal Revenue Service (IRS).
Plaintiff claims that procedural irregularities render the lien unlawful...
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