MEMORANDUM & ORDER
SAFFELS, District Judge.
This case is a contest between the Internal Revenue Service and the Lewis G. Allen Family Trust [hereinafter A Trust] over entitlement to a sum of money on deposit in a bank in Lenexa, Kansas. Plaintiff instituted a wrongful levy action under 26 U.S.C. § 7426(a)(3), seeking release of an escrow fund in the amount of Two Hundred Thirty-Five Thousand Dollars ($235,000), held by the Johnson County National...
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