JAMES C. HILL, Circuit Judge:
This appeal arises out of a priority dispute between the Internal Revenue Service (the Government) and the Citizens & Peoples National Bank of Pensacola, Florida (the Bank) over the proceeds of the general operating, checking account of Rosemont Nursing & Convalescent Home, Inc. (Rosemont).
The Government asserts priority to the proceeds of the account by virtue of a Notice
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