Appellant Capuano, an attorney, brought a wrongful levy action pursuant to 26 U.S.C. § 7426 against the Internal Revenue Service (IRS) to recover from seized funds the $25,000 fee due him as result of settlement of a forfeiture action between his client, Agustin Santana, and the United States. (United States District Court for the Northern District of Florida, Pensacola Division...
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