SCHWARZER, District Judge:
The United States brought this action under Section 3505(b) of the Internal Revenue Code, 26 U.S.C. § 3505(b), to collect from the First National Bank of Circle (Bank) the unpaid withholding and Federal Insurance Contribution Act (F.I.C.A.) taxes owed by Fort Belknap Builders, Inc. (Builders). The district court granted the Bank's motion for summary judgment, and the United States appeals. We reverse, having determined that the court...
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