United States of America, Appellant-Cross v. Park Cities Bank & Trust Company, Defendant-Appellee-Cross

AINSWORTH, Circuit Judge:

The United States sued Park Cities Bank and Trust Company under 26 U.S.C. § 3505(b) (1971) 1 to recover $17,099.74 withholding tax owed to the Government by one of the bank’s customers, Newby-Fitch and Associates, Inc., for the first three quarters of 1968. The district court granted judgment in favor of the Government for $11,427.75 attributable to the second quarter and $1,324.85 attributable to the third quarter, but failed to award recovery for $4,-347.14 attributable to the first quarter. The Government appeals insofar as the district court failed to grant…