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U. S. v. FIRST NAT. CITY BANK

No. 59.

379 U.S. 378 (1965)

UNITED STATES v. FIRST NATIONAL CITY BANK.

Supreme Court of United States.

Decided January 18, 1965.

Attorney(s) appearing for the Case

Assistant Attorney General Oberdorfer argued the cause for the United States. With him on the briefs were Solicitor General Cox and Harold C. Wilkenfeld.

Henry Harfield argued the cause for respondent. With him on the brief were William Harvey Reeves and John E. Hoffman, Jr.

Roy C. Haberkern, Jr., and Edward J. Ross filed a brief for the Chase Manhattan Bank et al., as amici curiae, urging affirmance.

Theodore Tannenwald and A. Chauncey Newlin filed a memorandum for Omar, S. A.

MR. JUSTICE DOUGLAS delivered the opinion of the Court.

This case presents a collateral phase of litigation involving jeopardy assessments of some $19,000,000 made by the Commissioner of Internal Revenue against Omar, S. A., a Uruguayan corporation. The assessments charged that income had been realized within the United States on which a tax was due. On the same day respondent was served with notice of levy and notice of the federal tax lien. At the same time petitioner...

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