HANSEN, Circuit Judge.
This is a lien priority dispute between a perfected security interest held by Bremen Bank and Trust Company (the Bank) and a federal tax lien. The Bank filed this action, seeking the return of funds levied and collected by the Internal Revenue Service (IRS) pursuant to a federal tax lien against Ingredient Transportation Company (Ingredient). The Bank claims the IRS's levies against Ingredient's contractual customers were wrongful because the...
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