MEMORANDUM
MERHIGE District Judge.
Plaintiff brings this action against the United States alleging wrongful levy upon property belonging to her. Jurisdiction is attained pursuant to 26 U.S.C. § 7426. The case is presently before the Court on plaintiff's motion for summary judgment. Both sides have submitted memoranda in support of their respective positions, and on the material before it the Court deems the matter ripe for disposition.
The pertinent...
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