MEMORANDUM OPINION AND ORDER
HAND, Chief Judge.
This cause is before the Court on the parties' cross-motions for summary judgment. The facts in this case are undisputed. Plaintiff, the United States of America, brought this action against the defendant, Metropolitan Life Insurance Company (Metropolitan) to enforce a levy. The Government specifically seeks a judgment against Metropolitan under 26 U.S.C. § 6332(c)(1) for the value of certain property...
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