Legal Opinion

United States v. State National Bank

Court of Appeals for the Second Circuit

Decided January 29, 1970No. 468, Docket 34142PublishedCited by 3 opinions

1Opinion of the Court

LEVET, District Judge.

This appeal involves the question of whether a District Court may award at*520torney’s fees to a bank-stakeholder from the funds in a taxpayer’s bank accounts when the amount in the accounts is substantially less than the amount awarded in judgment to the United States upon foreclosure of federal tax liens. We reverse the District Court’s judgment.

The facts are as follows:

On December 23, 1965, the United States filed a complaint in the United States District Court for the District of Connecticut against taxpayers Charles and Dorothy Wergeles for the purpose of reducing tax…

2Cases cited15 opinions

  1. Sprague v. Ticonic National BankSupreme Court of the United States · 1939
  2. In Re the Accounting of TottenNew York Court of Appeals · 1904
  3. Beaver v. . BeaverNew York Court of Appeals · 1889
  4. United States v. Liverpool & London & Globe InsuranceSupreme Court of the United States · 1955
  5. United States v. R. F. Ball Construction Co.Supreme Court of the United States · 1958

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3Cited by3 opinions

  1. Spinks v. JonesCourt of Appeals for the Fifth Circuit · 1974
  2. United States v. The State National Bank Of ConnecticutCourt of Appeals for the Second Circuit · 1970
  3. Paul G. Spinks and Mary E. Spinks v. J. L. Jones, Sr. And J. L. Jones, Jr. D/B/A J. L. Jones Construction Company v. United States of America, Intervenor-Appellant. No. 74-1373. Summary Calendar. Rule 18, 5th Cir. See Isbell Enterprises, Inc. v. Citizens Casualty Co. Of New York, 431 F.2d 409, PartCourt of Appeals for the Fifth Circuit · 1974

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