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As of March 15, 2018, SmithCo owed the IRS $3,000,000 in back taxes. SmithCo is a brokerage house that sells publicly traded securities to the

As of March 15, 2018, SmithCo owed the IRS $3,000,000 in back taxes. SmithCo is a brokerage house that sells publicly traded securities to the public. On March 15, 2018, the iRS properly filed a Notice of Federal Tax Lien (NFTL) that attached to all SmithCos property. On March, 30, 2018, without knowledge of the NFTL, William bought 500 shares of MATA Corp from SmithCo for $50,000. The MATA Corp shares were in Smith Cos inventory since February 8, 2018. RO Mike is assigned to administratively collect SmithCos tax liability. On April 18, 2018, RO Mike seized the MATA shares that William purchased from SmithCo in order to Satisfy SmithCOs outstanding tax liability. Did RO Mike have the legal right to seize the MataCorp shares that William purchased from SmithCo?

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