United States v. First National Bank of Arizona

MEMORANDUM AND ORDER

COPPLE, District Judge.

This is an action brought by the United States to enforce a levy for unpaid tax liability. Involved is a priority of claims to funds in a delinquent taxpayer’s bank account. The Government asserts a tax lien; the bank asserts a right of setoff. Both parties have moved for summary judgment on stipu lated facts and have filed memoranda setting forth their respective positions. A hearing on the motions was held before this Court on April 6, 1970, and subsequent to hearing the arguments of both parties the motions were taken under advisement.

This Court…