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The plaintiffs sued the United States under 26 U.S.C. § 7433, which authorizes damages claims for improper tax collection activities. The plaintiffs alleged that the IRS improperly filed a Notice of Federal Tax Lien related to a 1997 tax assessment that was made after the statute of limitations had run. The district court dismissed the complaint for failure to state a claim, finding that the plaintiffs were challenging the underlying tax assessment rather than the collection activity. The appellate court af
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- Scribd Government Docs
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- EN