MEMORANDUM ORDER
FISH, District Judge.
Plaintiff Commonwealth National Bank ("the Bank") alleges in this action that the United States, through the Internal Revenue Service ("IRS"), wrongfully levied upon certain real property. The Bank seeks return of the property. The United States and the Bank have each moved for summary judgment.
26 U.S.C. § 7426, which authorizes a civil action to redress a wrongful tax levy, provides that the assessment...
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