MEMORANDUM AND ORDER
SELYA, District Judge.
This is an action brought by the Newport National Bank ("Bank") against the United States, seeking to contest the efficacy of an Internal Revenue Service levy (the "Levy") on the demand deposits of Miracle Enterprises, Inc., a Rhode Island corporation ("Miracle"). The matter is before the Court on the defendant's motion to dismiss the Bank's second amended complaint, or in the alternative, to render judgment on...
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