who fails to comply with a levy, without reasonable cause, when required -to do so shall be liable to the government for a penalty in the amount of fifty percent of the amount recovered. Treas.Reg. § 301.6332-1(b)(2) finds reasonable cause where there is a bona fide dispute concerning the amount of property to be surrendered pursuant to the levy or the legal effectiveness of the levy. Although the regulation is unclear as to whether priority issues raise such bona fide disputes, cases interpreting the statute have found reasonable cause when a defendant has brought a wrongful levy action prior to remittance or where there was a dispute over the applicability of the defenses to a § 6332 claim. See supra p. 460-61. See United States v. Donahue Indus., Inc., 905 F.2d 1325 (9th Cir.1990) (<HOLDING>); Texas Commerce Bank-Fort Worth, N.A. v.
holding that one who acquires legal title with notice of a prior equitable interest in the property is not a bona fide purchaser holding that bona fide dispute over whether bank actually  possessed property belonging to taxpayer is reasonable cause recognizing that chapter 7 trustee as hypothetical bona fide purchaser takes title to the real property free from all equitable liens recognizing that if a creditors claim is subject to a bona fide dispute that creditor lacks standing to file an involuntary petition holding that a bona fide purchaser may be considered in privity with its predecessor