ORDER
SPIEGEL, Senior District Judge.
On January 16, 2003, Plaintiff Huffman, Carter & Hunt, Inc. filed the instant case pursuant to 26 U.S.C. § 6330(d), appealing a due process hearing determination that sustained the government's proposed levy to collect past-due payroll taxes (doc. 1). On May 27, 2003, Defendant United States of America moved this Court to summarily affirm the IRS Appeals Officer's determination sustaining the levy (doc. 5)....
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