Bell & Beckwith v. United States of America, Internal Revenue Service, Donna D. Cannon

KEITH, Circuit Judge.

This is an appeal from a judgment of the United States District Court for the Northern District of Ohio, distributing an inter-pleaded fund, less certain expenses, to the United States. For reasons stated below, we reverse the decision of the district court and remand with instructions to dismiss for lack of jurisdiction.

Facts

This case stems from an effort to collect the tax liabilities of Dr. Alan E. Zimmer. On August 28, 1981, the Internal Revenue Service (IRS) levied a tax lien on an investment account in the name of the appellant, Donna D. Cannon, and managed by…