Farmers State Bank of Mentone, Inc. v. United States, Internal Revenue Service

MEMORANDUM AND ORDER

MILLER, District Judge.

Plaintiff Farmers State Bank of Mentone loaned money to Sellers Motor Corporation, which in turn kept two deposit accounts at the plaintiffs bank. Sellers defaulted; Farmers State Bank demanded payment in full for all indebtedness and took possession of the collateral that secured the loan. Thereafter, the Internal Revenue Service seized Sellers’s accounts held by the bank to pay federal taxes that Sellers owed. The bank brought this suit to recover the funds, arguing that its position with regard to the balance of Sellers’s account is superior to…