OPINION
CALEB M. WRIGHT, Senior District Judge.
In December 1979 and January 1980, the Internal Revenue Service levied on property or rights to property of the taxpayer Retrospect, Inc. The notices of levy were served on the defendant who was believed to be in possession of such property. When defendant failed to surrender the property, plaintiff filed this suit to enforce the levy, pursuant to §§ 6332, 7401 and 7402 of the Internal Revenue Code...
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