MEMORANDUM OPINION AND ORDER
JULIAN ABELE COOK, Jr., District Judge.
On August 9, 1984, the United States brought suit against the Defendant, Palmer-Smith Company, for its failure to honor an Internal Revenue Service levy. In August of 1986, the Court allowed the Government to amend its Complaint and add a second cause of action (to wit, foreclosure of federal tax liens).
The issues were joined on September 23, 1986 when Palmer-Smith filed its answer...
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