United States v. National Bank of Commerce

ARNOLD, Circuit Judge.

The United States claims that one Roy J. Reeves has not paid all of his income tax for the year 1977. There are two bank accounts in the National Bank of Commerce of Pine Bluff, Arkansas, in the names of “Roy Reeves or Ruby Reeves or Neva R. Reeves.” The government served a notice of levy on the bank, demanding that enough of the accounts to satisfy the taxpayer’s obligation be paid over to it. The bank, protesting that it did not know how much of the account belonged to Roy, as opposed to Ruby or Neva, refused. The government then brought this action under Section…