The following excerpt is from U.S. v. Redevelopment Agency of City of Oakland, 111 F.3d 139 (9th Cir. 1997):
There are two defenses for failure to comply with a tax levy: 1) the party is not in possession of the taxpayer's property, or 2) the property is subject to a prior judicial attachment or execution. United States v. National Bank of Commerce, 472 U.S. 720, 721-22 (1985); Hemmen, 51 F.3d at 887-88.
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