Western Pennsylvania National Bank v. United States

OPINION

KNOX, District Judge.

Plaintiff has brought suit against the United States and the -Internal Revenue Service by a complaint entitled “Civil Action In the Nature of a Garnishment”. Paragraph 4 of the complaint states that it is “in the nature of a writ of garnishment ... to attach the surplus proceeds of levies, attachments and monies obtained in a pending inter-pleader suit filed by Coventry Care, which sums are owing to Contemporary Institute, Inc. and one or more of its wholly-owned subsidiaries. The attachment is to apply to all proceeds and money which comes in the possession of the…