Opinion for the Court filed by Circuit Judge KAVANAUGH.
KAVANAUGH, Circuit Judge:
For the 1994 tax year, Paul Keohane owed about $10,000 in federal income taxes for income he earned while working in Indonesia. He did not pay those taxes. To recover the unpaid taxes, the IRS eventually issued what is known as a single paper levy on Keohane's Social Security benefits. That paper levy automatically took nearly 40% of Keohane's monthly Social Security checks for...
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