ORDER
WILLIAM D. BROWNING, District Judge.
Pending before the Court is Defendant's June 30, 1994 Motion for Partial Summary Judgment. The Court will deny the Motion.
I. Facts and the Parties' Positions.
This is a wrongful levy action brought pursuant to 26 U.S.C. § 7426. Plaintiffs claim that certain real property, including a house, located in Tucson, Arizona, belongs to them and was improperly seized and levied...
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