MEMORANDUM OPINION
HULL, Chief Judge.
This is an action brought under 26 U.S.C. § 6332 by the Government to enforce a levy which was served on defendant, Murray's, Inc., by the IRS to collect delinquent income taxes of a third party, Virginia Cutshaw. This action came on for trial May 7, 1986, and the facts are basically undisputed. (See, Stipulated Facts, Court File No. 7).
Defendant Murray's, Inc. had an independent agent contract with...
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