Legal Opinion
Jefferson Bank and Trust v. United States
District Court, D. Colorado
Decided April 27, 1988No. Civ. A. 87-C-279PublishedCited by 2 opinions
1Opinion of the Court
ORDER
CARRIGAN, District Judge.
Plaintiff Jefferson Bank and Trust commenced this action alleging that the defendant, through the Internal Revenue Service, wrongfully levied upon a demand deposit account maintained at the plaintiff bank. Jurisdiction is predicated upon 28 U.S.C. § 1346(e) and 26 U.S.C. § 7426(a).
The material facts in this case are not in dispute. On October 15, 1984, the plaintiff pursuant to a promissory note, loaned $300,000 to William G. Coffee & Associates, Inc. (the “taxpayer”) and William G. Coffee individually. After an extension agreed to by the plaintiff, final payment…
2Cases cited16 opinions
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Aquilino v. United StatesSupreme Court of the United States · 1960
- United States v. Pioneer American InsuranceSupreme Court of the United States · 1963
- United States v. Sterling National Bank & Trust Company of New York, and Third-Party v. Charles S. Smith, Third-PartyCourt of Appeals for the Second Circuit · 1974
- Pittsburgh National Bank v. United StatesCourt of Appeals for the Third Circuit · 1981
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3Cited by2 opinions
- In Re WeningerUnited States Bankruptcy Court, D. Colorado · 1990
- Amaya v. SantistevanNew Mexico Court of Appeals · 1992