United States Bankruptcy Court, N.D. Alabama March 19, 1981, 19-00401 (United States v. Birco Mining Co. (In Re Birco Mining Co.))

OPINION

STEPHEN B. COLEMAN, Bankruptcy Judge.

The Government in this case in effect contends that after a levy under Sections 6321 and 6322, International Revenue Code of 1954, is made upon a taxpayer title to the property passes to the United States and such levy is an absolute appropriation in law, citing

United States v. Pittman,

449 F.2d 623, 626 (7th Cir.