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U.S. v. FIRST NAT. BANK AND TRUST CO.

Civ. A. No. 84-239.

695 F.Supp. 194 (1988)

UNITED STATES of America, Plaintiff, v. FIRST NATIONAL BANK AND TRUST COMPANY, Defendant.

United States District Court, W.D. Pennsylvania.

April 4, 1988.

Attorney(s) appearing for the Case

Craig R. McKay, Asst. U.S. Atty., Pittsburgh, Pa., Stuart M. Fischbein, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for plaintiff.

William M. Hoffman, Karlowitz, Sherman & Picadio, Pittsburgh, Pa., for defendant.

MEMORANDUM OPINION

DIAMOND, District Judge.

This is an action by the plaintiff to recover the value of certain property plus interest, costs and a penalty of fifty percent (50%) of that value pursuant to 26 U.S.C. § 6332(c)(1) and (2), as a result of defendant's failure to surrender on plaintiff's demand certain property of a delinquent taxpayer. The property in question is a $25,000 certificate of deposit made by Bert Gigli, Jr. ("taxpayer") to secure...

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