OPINION
CLARKSON S. FISHER, District Judge.
This is defendant's motion for summary judgment brought in an action which purportedly arises under 26 U.S. C.A. Section 7426, civil actions by persons other than taxpayers.
Plaintiff alleges that on March 12, 1970 Cen-Trific Air Products, a New York corporation doing business in New Jersey, entered into a Security Agreement with the Marine Midland Bank of
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