ORDER
EDWARD C. REED, Jr., Chief Judge.
Plaintiff, Evelyn Ketcham, moves the Court for issuance of a preliminary injunction to prohibit the I.R.S. from levying on certain assets pursuant to a levy served on Western Title Company, Inc., on May 16, 1991. An evidentiary hearing was held before the court on May 24, 1991. At that time the court also heard the arguments of counsel and received legal authority in support of the parties respective positions.
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