opinion: COOPER AGENCY, INC., et al., Appellants, v. Harold M. McLEOD, District Director of Internal Revenue and United States of America, Appellees.
  No. 9871.
  United States Court of Appeals Fourth Circuit.
  Argued May 4, 1965.
  Decided Aug. 4, 1965.
  Robert J. Thomas and N. Welch Mor-risette, Jr., Columbia, S. C. (Gedney M. Howe, Jr., Arthur G. Howe, Charleston, S. C., Tompkins, McMaster & Thomas, and Cooper, Gary, Nexsen & Pruet, Columbia, S. C., on brief), for appellants.
  George F. Lynch, Attorney, Department of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson and Meyer Rothwacks, Attorneys, Department of Justice, and Terrell L. Glenn, U. S. Atty., on brief), for appellees.
  Before HAYNSWORTH, Chief Judge, and BOREMAN and BRYAN, Circuit Judges.
  PER CURIAM:
  The plaintiffs seek to test their tax liabilities in an action for an injunction and for removal of the cloud cast upon their properties by the tax liens. The judgment of the District Court dismissing these complaints is affirmed for the reasons stated by the District Judge
  We recently considered similar contentions and held them unavailing. At about the same time the Second and Third Circuits arrived at the same conclusion.
  Affirmed.
  . 235 F.Supp. 276.
  . Broadwell v. United States, 4 Cir., 343 F.2d 470.
  . Falik v. United States, 2 Cir., 343 F.2d 38; Quinn v. Hook, 3 Cir., 341 F.2d 920.
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private business (including criminal enterprises)", specifically "unclear". Your task is to determine what subcategory of business best describes this litigant.
choices: auto industry chemical industry drug industry food industry oil & gas industry clothing & textile industry electronic industry alcohol and tobacco industry other unclear