LOGAN, Circuit Judge.
Ronald and Kay James (plaintiffs) appeal summary judgment against them in their quiet title action against the United States under 28 U.S.C. § 2410. Although plaintiffs claimed procedural irregularities in the tax levy on Mr. James' wages, the district court found that the case was, at heart, a challenge of the tax liability for which the levy was established and held that it had no jurisdiction to hear the matter. It then entered summary...
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