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V.I. BUREAU OF INT. REV. v. CHASE MANHATTAN BANK

No. 01-3467, 01-3468, 01-4325, 01-4326, 01-4464.

312 F.3d 131 (2002)

VIRGIN ISLANDS BUREAU OF INTERNAL REVENUE Appellant v. CHASE MANHATTAN BANK, Defendant/Third-party Plaintiff Appellant v. William Lansdale, Third-Party Defendant Appellant

United States Court of Appeals, Third Circuit.

Filed December 5, 2002.

Attorney(s) appearing for the Case

Lawrence M. Hill (Argued), Michael I. Saltzman, Richard A. Nessler, White & Case LLP, New York, NY, for Appellant Chase Manhattan Bank.

Iver A. Stridiron, Attorney General, Elliott McIver Davis, Solicitor General, Joanne E. Bozzuto (Argued), Special Assistant Attorney General, Richard M. Prendergast, Assistant Attorney General, Office of Attorney General of Virgin Islands, Department of Justice, Charlotte Amalie, St. Thomas, USVI, John A. Sopuch, III, Sopuch Nouhan Higgins Arnett & Gaubert, Chicago, IL, John A. Zebedee, Hymes & Zebedee, Charlotte Amalie, St. Thomas, USVI, for Appellee Virgin Islands Bureau of Internal Revenue.

Henry C. Smock (Argued), Smock Law Offices, Charlotte Amalie, St. Thomas, USVI, Richard Smith, Cynthia Morales, Shook, Hardy & Bacon LLP, Miami, FL, for Appellee William Lansdale.

Before AMBRO, FUENTES and GARTH, Circuit Judges.

OPINION OF THE COURT

AMBRO, Circuit Judge.

This case poses two questions. First, does senior bank officers' knowledge that the company named in a notice of levy previously had merged into another company neither named nor identified in the levy notice require the bank to enforce the levy against the company not named in the notice? Under the circumstances of this case, we hold that it does not. Second, must a bank honor a notice of levy on property in which...

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