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PEOPLES NAT. BANK OF WASHINGTON v. U.S.

No. 85-3514.

777 F.2d 459 (1985)

PEOPLES NATIONAL BANK OF WASHINGTON, a national banking association, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided November 25, 1985.

Attorney(s) appearing for the Case

James L. Austin, Jr., Bernard H. Friedman, Karr, Tuttle, Koch, Campbell, Mawer & Morrow, Seattle, Wash., for plaintiff-appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Steve Frahm, Dept. of Justice, Washington, D.C., for defendant-appellee.

Before SNEED, SCHROEDER, and BRUNETTI, Circuit Judges.

SCHROEDER, Circuit Judge.

Peoples National Bank of Washington brought this action against the United States, asking the district court to declare that the United States' tax levy against a depositor's account was invalid. The district court dismissed the action on the ground that the bank had no interest in the account superior to that of the government. In this appeal, the bank argues that its rights in the account are superior by virtue of either its common law...

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