PER CURIAM:
This is an appeal from the decision of a magistrate judge that a levy imposed by the Internal Revenue Service ("IRS") on bank accounts of Oxford Capital Corporation ("Oxford") to satisfy tax liabilities of one of its subsidiaries was not a wrongful levy under 26 U.S.C. § 7426. Oxford filed this appeal, contending that the magistrate judge erred both in its application of the applicable standard and in its factual findings. For the reasons discussed...
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