United States v. First National City Bank, and Milton F. Meissner, Proposed Intervenor-Appellant

TIMBERS, Circuit Judge:

This appeal presents questions important to the administration of the internal revenue laws. They arise from the use of summary judicial proceedings to enforce IRS levies upon the contents of a taxpayer’s safe deposit box following a determination by the IRS that the collection of back taxes from the taxpayer is in jeopardy. The central issue is whether the taxpayer’s constitutional rights require that as a pre -seizure remedy he be granted leave to intervene in the summary enforcement proceedings or whether the taxpayer’s post -seizure remedies are adequate to protect…