United States v. Boardwalk Motor Sports, Ltd.

JERRY E. SMITH, Circuit Judge:

A bank named Plains Capital Corporation (“Plains Capital”) and Boardwalk Motor Sports, Limited (“Boardwalk”), appeal a judgment finding them liable for conversion of the proceeds from the sale of a car *380that was subject to a tax lien. Boardwalk sold the car and gave the proceeds to Plains Capital to get Plains Capital to release the title, and Plains Capital applied the money to the taxpayer’s debt. The IRS attempted to obtain the proceeds by levy after Plains Capital had applied the money to the debt, so Plains Capital claimed it no longer had any of the…