the District Court’s order improperly burdens his social security benefits. ¶20 Based on the evidence introduced at sentencing, including the testimony of accountants Bateson and Newberg, the District Court ordered Eaton to pay $114,520.32 in restitution. The court ordered Eaton to make payments of 20 percent of his net income and indicated that net income includes income from any source including social security or retirement benefits. ¶21 However, the District Court’s order conflicted with § 407(a), which provides that “none of the moneys paid or payable ... under [the Social Security Act] shall be subject to ‘execution,’ ‘levy,’ ‘attachment,’ ‘garnishment,’ or other ‘legal process.’ ” See also Bennett v. Arkansas (1988), 485 U.S. 395, 396, 108 S.Ct. 1204, 1205, 99 L.Ed.2d. 455, 458 (<HOLDING>); Philpott v. Essex County Welfare Bd. (1973),
holding that the express language of  407a and the clear intent of congress that social security benefits not be attachable holding that under 42 usc  407a social security benefits commingled with other nonexempt funds in a bank account remain exempt if the funds are reasonably traceable to social security income holding that offset for social security retirement benefits does not include federal disability benefits and stating that there was no legislative intent to embody the entire subchapter of the social security act dealing with both disability benefits and old age benefits holding that under 42 usc  407a social security benefits commingled with other nonexempt funds in a bank account remain exempt if the funds are reasonably traceable to social security income on a firstin firstout basis holding that  407a imposes a broad bar against the use of any legal process to reach all social security benefits