OPINION AND ORDER
ELLIOTT, District Judge.
In this civil action Plaintiff, a banking corporation with its principal place of business in Columbus, Georgia, seeks to recover the amounts it paid to Defendant, the United States of America, pursuant to a Notice of Levy served upon Plaintiff by the Internal Revenue Service. The amounts involved were deposited with Plaintiff by a customer who was delinquent in paying federal FICA, withholding and unemployment...
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