Bank of America National Trust & Savings Association, a National Banking Association v. United States

317 F.2d 859 BANK OF AMERICA NATIONAL TRUST & SAVINGS ASSOCIATION, a National Banking Association, Appellant, v. UNITED STATES of America, Appellee. No. 18142. United States Court of Appeals Ninth Circuit. May 24, 1963. Samuel B. Stewart, Robert H. Fabian and Alfred T. Twigg, Los Angeles, Cal., for appellant. Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Joseph Kovner and Fred E. Youngman, Attorneys, Department of Justice, Washington, D. C., Francis C. Whelan, U. S. Atty., Walter S. Weiss, Asst. U. S. Atty., Chief, Tax Section, and Herbert D. Sturman, Asst. U. S. Atty., Los Angeles, Cal., for appellee. Before CHAMBERS and BARNES, Circuit Judges, and WEIGEL, District Judge. CHAMBERS, Circuit Judge. 1 J. B. Edmondson in August, 1959, was a customer of the Bank of America at its West Orangethorpe Road office in Fullerton, Orange County, California. Credit balances owed him by the bank on August 27, 1959, which, if there were no liens or set-offs, all would agree, amounted to $6,658.31. 2 Dating from 1955 to and including August 27, 1955, the government (the Internal Revenue Service) had balances due from the bank's customer Edmondson in excess of eight thousand dollars…