Virgin Islands Bureau of Internal Revenue v. Chase Manhattan Bank, Defendant/third-Party v. William Lansdale, Third-Party

OPINION OF THE COURT

AMBRO, Circuit Judge.

This case poses two questions. First, does senior bank officers’ knowledge that the company named in a notice of levy previously had merged into another company neither named nor identified in the levy notice require the bank to enforce the levy against the company not named in the notice? Under the circumstances of this case, we hold that it does not. Second, must a bank honor a notice of levy on property in which it holds an unexercised right of setoff, but has limited the property owner’s access? We hold that because an account holder retains a…