MEMORANDUM AND ORDER
KOPF, District Judge.
Pending before me are cross-motions for summary judgment (filings 14 & 18). Plaintiffs, two Nebraska law firms ("Law Firms"), have sued the United States of America. The Law Firms assert that the Internal Revenue Service (IRS) levied upon two stock certificates that were then in the hands of the Clerk of the District Court of Lincoln County, Nebraska, and that the levy violated 26 U.S.C. § 7426. I will...
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