Bregman, Berbert & Schwartz, L.L.C. Douglas M. Bregman v. United States of America, Alan F. Post, Movant

Affirmed in part, vacated in part, and remanded by published opinion. Judge HAMILTON wrote the opinion, in which Chief Judge WILKINSON and Judge MICHAEL joined.

OPINION

HAMILTON, Circuit Judge:

This appeal involves a wrongful levy action against the United States brought by the law firm of Bregman, Berbert & Schwartz, L.L.C. (the Bregman Firm) and attorney Douglas Bregman to recover $104,000 the United States used to partially satisfy delinquent federal taxes owed by a second law firm, Alan F. Post, Chartered (the Post Firm). At the time of the levy, the $104,000 was on deposit in a bank account…