Plaintiff Thomas Dean had a checking account with defendant NationsBank ("the bank"). When Dean failed to pay his federal income taxes, the IRS served the bank with a notice of levy. See 26 USCA §§ 6331 & 6332. After notifying Dean and waiting 21 days as required by § 6332(c), the bank complied with the levy and surrendered the money in Dean's account to the IRS. Despite notification...
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