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http://nycourts.law.com/CourtDocumentViewer.asp?view=Document&docID=46877 Judge Conner PLAINTIFF, PUBLISHER of a newspaper that focuses on matters of interest to the black community, published an article addressing a discrimination action against the IRS. The IRS later announced it was auditing plaintiff, and during a meeting an IRS employee criticized the publication’s content. After defendant completed the audit, he used coercive tactics to persuade plaintiff to sign a report containing false findings and then filed the report after plaintiff refused to do so. Another defendant caused tax liens to be filed against plaintiff, as a result of which plaintiff has been unable to conduct business. Plaintiff later brought a Bivens action against individual defendants as IRS employees. The court, among other things, dismissed plaintiff’s Fourth Amendment claims, finding that although it claimed that defendant seized its accountant’s records, plaintiff failed to allege that its property was seized in the course of a warrantless search or that the agents seizing the property were acting under a defective warrant.

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