OPINION
FRYE, District Judge:
The matters before the court are 1) the United States' motion for summary judgment (# 31); and 2) the plaintiffs' motion for summary judgment (# 36).
BACKGROUND
The plaintiffs bring this action under 26 U.S.C. § 7426 against the United States of America alleging that the Internal Revenue Service (IRS) wrongfully levied upon and seized funds deposited in the United States National Bank of Oregon, Account...
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