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UNITED STATES v. NATIONAL BANK OF COMMERCE

No. 84-498.

472 U.S. 713 (1985)

UNITED STATES v. NATIONAL BANK OF COMMERCE

Supreme Court of United States.

Decided June 26, 1985

Attorney(s) appearing for the Case

Albert G. Lauber, Jr., argued the cause for the United States. With him on the brief were Solicitor General Lee, Assistant Attorney General Archer, William S. Estabrook, and John A. Dudeck, Jr.

Terry F. Wynne argued the cause and filed a brief for respondent.

JUSTICE BLACKMUN delivered the opinion of the Court.

Section 6331(a) of the Internal Revenue Code of 1954, as amended, 26 U. S. C. § 6331(a), provides that the Government may collect taxes of a delinquent taxpayer "by levy upon all property and rights to property . . . belonging to such person."1 Section 6332(a) of the Code, 26 U. S. C. § 6332(a), then provides that "any person in possession...

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