United States v. Bank of America National Trust & Savings Ass'n

CLARKE, District Judge.

This action involves priority of claims to funds in a taxpayer’s bank accounts. The United States asserts a lien right; and the defendant bank asserts a statutory right of setoff. There is no dispute as to the facts, both parties having moved for summary judgment.

The taxpayer, J. B. Edmondson, maintained accounts with defendant bank at a branch office in Fullerton, Orange County, California. The accounts stood in the taxpayer’s own name and in certain business names. For aught that appears in the record, the businesses were sole proprietorships. The-accounts have been…