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AMERICAN TRUST v. AMERICAN COMMUNITY MUT. INS. CO.

No. 97-3385.

142 F.3d 920 (1998)

AMERICAN TRUST, Plaintiff, v. AMERICAN COMMUNITY MUTUAL INSURANCE COMPANY, Defendant, AMERICAN COMMUNITY MUTUAL INSURANCE COMPANY, Plaintiff, v. UNITED STATES of America, INTERNAL REVENUE SERVICE, Defendant-Appellee, Edgar F. Bradley, II, Defendant-Appellant, Richard A. Davidson, Defendant.

United States Court of Appeals, Sixth Circuit.

Decided April 27, 1998.

Attorney(s) appearing for the Case

Richard John Donovan (argued and briefed), Richard J. Donovan & Associates, Worthington, OH, for Defendant-Appellant.

Michael W. Davis, U.S. Department of Justice, Tax Division, Washington, DC, Jan M. Holtzman, Asst. U.S. Attorney, cincinnati, OH, William S. Estabrook (briefed), Pamela C. Berry (argued and briefed), U.S. Department of Justice, Appellate Section, Tax Division, Washington, DC, for Defendant-Appellee.

Before: KENNEDY and SILER, Circuit Judges; COHN, District Judge.

OPINION

KENNEDY, Circuit Judge.

Defendant Edgar F. Bradley, II, appeals the District Court's order granting summary judgment in favor of the United States in these consolidated breach of contract and interpleader actions. In its complaint in the interpleader action, the United States sought enforcement of tax liens against insurance sales commissions attributable to defendant. The District Court held that the Government had valid tax liens under 26 U.S.C...

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