RULING ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
W. EUGENE DAVIS, District Judge.
The parties filed cross-motions for summary judgment raising the legal issue of whether the IRS may levy on the wages of a seaman to satisfy the seaman's tax liabilities.
FACTS
The defendant owns and operates vessels. From March 2, 1977, through May 21, 1978, Joseph W. Adair, Jr., was employed by the defendant as a master of various vessels.
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