MEMORANDUM OPINION
JOE LEE, Bankruptcy Judge.
This case is before the court on the motion of the trustee for summary judgment against the Internal Revenue Service and International Business Machines Corporation and on the motion of the United States of America for summary judgment against the trustee. In order to rule on these motions, the court must determine whether, as a matter of law, an account receivable levied on by the Internal Revenue Service prior...
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