OPINION
WOOD, Judge.
Plaintiff, in her capacity as Trustee of a family trust (Trustee), sought damages from defendant on the basis of its response to a notice of tax levy from the United States Department of the Treasury, Internal Revenue Service (IRS). Defendant moved to dismiss, relying on a federal court judgment. The trial court granted the motion; Trustee appealed. We discuss: (1) the procedural posture; (2) the effect of the federal judgment; and ...
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