FRANK A. KAUFMAN, District Judge:
Taxpayers (plaintiffs-appellants) appeal from the judgment below, denying to them, in the summary judgment context of this case, the return, which they seek, of certain monies seized by the Internal Revenue Service (IRS). For the reasons set forth in this opinion, we affirm.
The facts in this case are undisputed. On or about April 12, 1982, the IRS assessed $132,327.06 against each of the two taxpayers for nonpayment of federal...
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