She filed this action on November 29, 2004, against the Internal Revenue Service ("IRS"), seeking declaratory and injunctive relief, and also seeking damages. Plaintiff alleges that prior to 1997, she owed approximately $78,000 in federal taxes, penalties, and interest. She claims that starting in 1997 the IRS began levying on her bank accounts and on health plans that owed her money for professional services, without providing her with a deficiency notice prior to each assessment, in violation of 26 U.S.C. §§ 6212(a) and 6313(a).*fn1 She asserts that as of the time of the filing of the complaint, the IRS had executed levies in the amount of $196,029.80.