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FIRST PEOPLES BANK v. U.S.

No. CIV-3-91-0693.

806 F.Supp. 187 (1992)

FIRST PEOPLES BANK OF JEFFERSON COUNTY, TENNESSEE, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Tennessee, at Knoxville.

August 14, 1992.

Attorney(s) appearing for the Case

Dale C. Allen, Baker, Worthington, Crossley, Stansberry, & Woolf, Knoxville, Tenn., for plaintiff.

William K. Rounsborg, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

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...

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