In Re Tax Refund Litigation

MEMORANDUM AND ORDER

PLATT, Chief Judge.

Plaintiffs in the Cohen and Barrister actions move this Court to enforce Internal Revenue Code (“I.R.C.”) § 6703(c). 1 Specifically, plaintiffs request that this Court (i) order the government to remove the notices of federal tax liens that the govern ment has filed against plaintiffs, (ii) enjoin the government from filing any further notices of federal tax liens against plaintiffs, and (iii) release the income tax refunds of plaintiffs. In response, the government argues that § 6703(c)(1) only prohibits the IRS from “levying” or “proceeding in court”.…