If a person, partnership, corporation, limited liability company, limited liability partnership or other legal entity fails or refuses to respond to the levy within fifteen (15) days of the date the person, partnership, corporation, limited liability company, limited liability partnership or other legal entity is served with the levy, the Commissioner may commence legal proceedings against the person to collect the full amount of the overpayment owed up to the value of the assets that are under the control of the person upon whom the levy is served at the time of service and thereafter.
219 Neb. Admin. Code, ch. 18, § 002