Legal Opinion
First Peoples Bank v. United States
District Court, E.D. Tennessee
Decided August 14, 1992No. CIV-3-91-0693Published
1Opinion of the Court
MEMORANDUM OPINION
JORDAN, District Judge.
This is a civil action under 26 U.S.C. § 7426 in which the plaintiff bank contends that the defendant United States, acting through the Internal Revenue Service, wrongfully levied on property against which the bank had at the time of the levy a prior lien. The action is before the court for consideration of the United States’ motion to dismiss [doc. 7], in support of which the United States argues that the claimed lien was inchoate, and therefore inferior to the tax lien for the enforcement of which levy was had.
The court heard oral argument on this…
2Cases cited9 opinions
- United States v. Kimbell Foods, Inc.Supreme Court of the United States · 1979
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- G. M. Leasing Corp. v. United StatesSupreme Court of the United States · 1977
- United States v. Pioneer American InsuranceSupreme Court of the United States · 1963
- Aetna Insurance Company v. Texas Thermal Industries, Inc. v. Small Business AdministrationCourt of Appeals for the Fifth Circuit · 1979
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