MEMORANDUM OPINION
DIAMOND, District Judge.
By this interpleader action, the court is called upon to determine whether the government is authorized to levy certain Individual Retirement Accounts of Melvin and Mildred Goldman (hereafter, Goldmans) which were deposited with the First Federal Savings and Loan Association of Pittsburgh (hereafter, First Federal). Presently before the court is the motion for summary judgment filed on behalf of the government...
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