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This case addressed the validity of the
Department of Revenue's tax levy of a bank account.
Plaintiff, the trustee of an indenture trust, claimed
that the bank account did not belong to the taxpayer,
but instead was the property of six classes of the
taxpayers' creditors for whose benefit the trust was
established. The Court rejected this argument. In
addition, the Court held that even if the |
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trustee had a right to the bank account,
the DOR's lien took priority because the lien took
effect at a time when the UCC financing statements of
the trustee had lapsed.
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