No. 90-6004.

932 F.2d 490 (1991)

CITIZENS STATE BANK, Plaintiff-Appellant, v. UNITED STATES of America, on Behalf of its INTERNAL REVENUE SERVICES; Liberty National Bank, Defendants-Appellees.

United States Court of Appeals, Sixth Circuit.

Decided May 2, 1991.

Attorney(s) appearing for the Case

Ronald J. Bamberger, Bamberger & Abshier, Owensboro, Ky., for Citizens State Bank.

Joseph M. Whittle, U.S. Atty., Scott C. Cox, Office of the U.S. Atty., Louisville, Ky., Gregory S. Hrebiniak, Gary R. Allen, Acting Chief, David English Carmack, Doris D. Coles, U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, D.C., for U.S.

M. Deane Stewart, Morgan & Pottinger, Louisville, Ky., for Liberty Nat. Bank.

Before JONES and SUHRHEINRICH, Circuit Judges, and FEIKENS, Senior District Judge.


Plaintiff Citizens State Bank ("CSB") appeals the district court's declaratory judgment finding that a federal tax lien is superior to CSB's lien against funds remaining in an escrow account. For the reasons that follow, we affirm.


This action arises out of a lien priority dispute between CSB and the United States, on behalf of the Internal Revenue Service ("IRS"), as to distribution of the proceeds from real estate formerly owned...

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