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U.S. v. CENTRAL BANK OF DENVER

No. 84-1050.

843 F.2d 1300 (1988)

UNITED STATES of America, Plaintiff-Appellant, v. CENTRAL BANK OF DENVER, Defendant-Appellee.

United States Court of Appeals, Tenth Circuit.

March 31, 1988.

Attorney(s) appearing for the Case

Murray S. Horwitz, Tax Div., Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Washington, D.C., Michael L. Paup, and Carleton D. Powell, Tax Div., Dept. of Justice, Washington, D.C., were also on the brief, Robert N. Miller, U.S. Atty., Denver, Colo., of counsel), for plaintiff-appellant.

Alice L. Parker, Denver, Colo. (Cheryl A. Crandall, Denver, Colo., was also on the brief), for defendant-appellee.

Before HOLLOWAY, Chief Judge, LOGAN, Circuit Judge, and BRETT, District Judge.

HOLLOWAY, Chief Judge.

The plaintiff-appellant, the United States of America, appeals from the district court's memorandum opinion and judgment holding that the appellee, the Central Bank of Denver, properly refused to honor an Internal Revenue Service, levy served upon the bank because it had a perfected security interest in the delinquent taxpayer's bank account. The appellant (the "Government") filed a timely appeal. We reverse.

I

A. The factual...

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