Interfirst Bank Dallas, N.A. v. United States of America, and Internal Revenue Service, Defendants

GOLDBERG, Circuit Judge:

This case requires us to apply the hoary and oft-criticized doctrine of sovereign immunity. On November 4, 1982, Interfirst Bank Dallas filed suit against the United States and the Internal Revenue Service alleging that the IRS, in collecting delinquent taxes from the Condor Drilling Company, wrongfully levied upon property in which Interfirst had a perfected security interest. After severing part of Inter-first’s claim, the district court dismissed the remaining portion of the claim on the ground that sovereign immunity applied. Because we agree that the government is…