CONTIE, Circuit Judge.
The Bank of Celina, the defendant, appeals from a district court judgment in favor of the United States in this action originally brought to foreclose on tax liens and to enforce a levy. The liens and levy had resulted from the failure of RBS Sportswear, Inc. (RBS), the taxpayer, to pay federal employment taxes. The district court held the Bank of Celina liable for not surrendering RBS property to which the government was entitled because of...
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