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 plaintiff's 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...
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