Continuing Priority Battle: Bank Security Interest V. IRS Tax Lien

LexisNexis (September 25, 2019, 2:14 PM EDT) -- Suppose ABC Corp. grants its bank a security interest in a CD issued by that bank, then merges with XYZ Corp. A year later the IRS hits XYZ’s bank with a notice of tax levy, using ABC’s corporate name and tax ID number. Can the depository bank ignore the levy because it identified a nonexistent taxpayer? If the IRS levies under the proper name, can the bank ignore the levy and exercise setoff against the CD? These two issues were before the Third Circuit. The bank won on the first issue, but lost on the second....