United States v. National Bank of Commerce

Section 6331(a) of the Internal Revenue Code of 1954, as amended, 26 U. S. C. § 6331(a), provides that the Government may collect taxes of a delinquent taxpayer “by levy *715upon all property and rights to property . . . belonging to such person.”1 Section 6332(a) of the Code, 26 U. S. C. § 6332(a), then provides that “any person in possession of (or obligated with respect to) property or rights to property subject to levy upon which a levy has been made shall, upon demand of the Secretary, surrender such property or rights . . . to the Secretary.”2

The controversy in this case concerns two joint…