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SMITH v. EGGAR

No. 74-1149.

655 F.2d 181 (1981)

C. Arnholt SMITH, British Columbia Investment Company and Westward Realty Company, Plaintiffs-Appellees, v. Roscoe L. EGGAR, Commissioner of Internal Revenue, and William H. Connett, District Director of Internal Revenue, Defendants-Appellants.

United States Court of Appeals, Ninth Circuit.

Resubmitted September 14, 1979.

Decided August 31, 1981.

As Corrected September 16, 1981.

Attorney(s) appearing for the Case

Robert E. Lindsay, Washington, D. C., for defendants-appellants.

Thomas Sheridan, Simon, Sheridan, Murphy, Thornton & Hinerfeld, Los Angeles, Cal., for plaintiffs-appellees.

Before CHAMBERS and GOODWIN, Circuit Judges and TAYLOR, District Judge.

Resubmitted After Two Intervening Remands September 14, 1979.

CHAMBERS, Circuit Judge:

On August 1, 1973, the Internal Revenue Service filed a jeopardy assessment in excess of twenty-two million dollars, for the single tax year of 1969, against C. Arnholt Smith. Two days later, specific and general levies were served on many persons and entities, including one on the United States National Bank (hereafter "the Bank...

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