Farmers-Peoples Bank v. United States

This appeal involves the claim of the plaintiff, Farmers-Peoples Bank of Milan, Tennessee (the bank) against the defendant, the United States (the government) pursuant to 26 U.S.C. § 7426(a) (1) for an alleged wrongful levy by the government on the assets of the Clemmer Building Supply Company (C.B.S.), now bankrupt. The government counterclaimed under 26 U.S.C. § 3505(b), which imposes personal liability on lenders under certain conditions. The district court for the Western District of Tennessee partially granted the relief sought by each party. The plaintiff has appealed and the government has cross-appealed.