ORDER
HODGES, District Judge.
This action to enforce a tax levy is before the Court on the parties' cross-motions for summary judgment (Docs. 12, 18). Each party has responded to the motion of the other. For the reasons that follow, Plaintiff's motion for summary judgment will be granted and Defendant's motion will be denied.
BACKGROUND
Because the Court's resolution of the case does not turn on the complex priority issues...
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