Court of Appeals for the Sixth Circuit November 15, 1983, 82-5337 (United States v. Bank of Celina)

CONTIE, Circuit Judge.

The Bank of Celina, the defendant, appeals from a district court judgment in favor of the United States in this action originally brought to foreclose on tax liens and to enforce a levy. The liens and levy had resulted from the failure of RBS Sportswear, Inc. (RBS), the taxpayer, to pay federal employment taxes.