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UNITED STATES v. MERCHANTS NAT. BANK OF MOBILE

Nos. 84-7513, 84-7522.

772 F.2d 1522 (1985)

UNITED STATES of America, Plaintiff-Appellant, Cross-Appellee, v. MERCHANTS NATIONAL BANK OF MOBILE, Defendant-Appellee, Cross-Appellant.

United States Court of Appeals, Eleventh Circuit.

October 7, 1985.

Attorney(s) appearing for the Case

Glenn L. Archer, Asst. Atty. Gen., Tax Div., Dept. of Justice, Michael L. Paup, Chief, Appellate Section, Farley Katz, Wynette J. Hewett, Washington, D.C., for plaintiff-appellant, cross-appellee.

Brock B. Gordon, Alan Christian, Mobile, Ala., for defendant-appellee, cross-appellant.

Before RONEY and FAY, Circuit Judges, and DUMBAULD, District Judge.

PER CURIAM:

The United States appeals the district court's order granting summary judgment in favor of the defendant, Merchants National Bank of Mobile (MNB). MNB cross-appeals the district court's order denying its first motion for summary judgment. For the reasons which follow, we affirm the district court in all respects.

I. BACKGROUND

On March 18, 1983, the United States brought this action alleging that under 26 U.S.C. § 3505(a) & ...

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