Court of Appeals for the Eighth Circuit December 19, 1997, 96-2433 (Bremen Bank and Trust Company v. United States)

HANSEN, Circuit Judge.

This is a lien priority dispute between a perfected security interest held by Bremen Bank and Trust Company (the Bank) and a federal tax lien. The Bank filed this action, seeking the return of funds levied and collected by the Internal Revenue Service (IRS) pursuant to a federal tax lien against Ingredient Transportation Company (Ingredient).