MEMORANDUM OPINION AND DECISION
LOREN S. DAHL, Chief Judge.
FACTS
Prior to the filing of their chapter 13 petition, Ray D. and Melody A. Paul had two bank accounts, one established at Placer Savings and Loan and the other at the Bank of Alex Brown. On December 8, 1987, the California State Board of Equalization (Board) served notices of levy on the two banks pursuant to Cal.Rev. & Tax Code sec. 6703.
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