MEMORANDUM OPINION
THOMAS W. WALDREP, JR., Bankruptcy Judge.
This adversary proceeding was tried on August 22, 2011. Anne E. Blaess appeared on behalf of the above-captioned defendant (the "IRS"), and W.Y. Alex Webb and Jason A. Morton appeared on behalf of the above-captioned plaintiff ("Schofield-Johnson"). In this case, the IRS filed a lien and levied upon an account belonging to Schofield-Johnson, with the intent to use these funds to pay a tax...
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