MEMORANDUM OF DECISION
MURTHA, Chief Judge.
The plaintiffs, Earll and Carol Holden (hereinafter "the Holdens"), appeal the Bankruptcy Court's dismissal of their complaint against the Internal Revenue Service ("IRS") for failure to state a claim upon which relief can be granted. In the instant adversary proceeding, the plaintiffs challenge the right of the IRS to place an administrative freeze on their 1996 tax refund. For the reasons set forth below...
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