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possession of the Government”); United States v. Whiting Pools,
Inc., supra at 211. In United States v. Natl. Bank of Commerce,
supra at 731 n.15, the Supreme Court stated that a “levy does not
purport to determine any rights to the property. It merely
protects the Government’s interests so that rights to the
property may be determined in a postseizure proceeding.”
The liability created by a levy on a third party is
discharged when the third party honors the levy. See id. at 721.
Cash v. United States, 961 F.2d at 567, states that “when the
levied upon property is a debt owed to the taxpayer, such as an
account receivable, the levy may be satisfied by paying over to
the Government the money owed to the taxpayer.” See also sec.
6332(a), (d);9 sec. 301.6332-1(a)(1), Proced. & Admin. Regs.10
9Sec. 6332(a) provides:
SEC. 6332. SURRENDER OF PROPERTY SUBJECT TO LEVY
(a) Requirement.-–Except as otherwise provided in
this section, any person in possession of (or obligated
with respect to) property or rights to property subject
to levy upon which a levy has been made shall, upon
demand of the Secretary, surrender such property or
rights (or discharge such obligation) to the Secretary,
except such part of the property or rights as is, at
the time of such demand, subject to an attachment or
execution under any judicial process.
10Sec. 301.6332-1(a)(1), Proced. & Admin. Regs., provides:
Surrender of Property Subject to Levy.--(a) Requirement.-–
(1) In general.–Except as otherwise provided in � 301.6332-2,
relating to levy in the case of life insurance and endowment
contracts, and in � 301.6332-3, relating to property held by
banks, any person in possession of (or obligated with respect
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