GARWOOD, Circuit Judge:
Capitol Indemnity Corporation (Capitol) appeals the adverse summary judgment in its wrongful levy action against the United States and the Commissioner of the Internal Revenue Service (IRS). Because the government did not show that the liable taxpayer had a right to the property levied against, we reverse and render judgment in favor of Capitol.
Facts and Proceedings Below
Beginning in 1999, Capitol acted as a surety for M...
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