ANDERSON, Circuit Judge:
Defendant-appellant Andrea A. Ruff appeals the judgment of the district court, on summary judgment, in favor of plaintiff-appellee the United States of America in the amount of $20,000, arising from Ruff's failure to honor an Internal Revenue Service ("IRS") levy on property or rights to property of a delinquent taxpayer in her possession. United States v. Andrea A. Ruff,
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