argument is equally unavailing. Defendant contends that Treas.Reg. § 301.6323b — l(j) and the concomitant example establish that Defendant was only required to remit to the IRS the amount in excess of that to which it was entitled pursuant to its security interest in the account. This regulation interprets 26 U.S.C. § 6322 which deals with the validity and priority of IRS liens as against certain individuals.' § 6332 and the eases interpreting it clearly establish that priority issues are not litigable in actions to enforce a tax levy. Consequently, this argument also fails and the government is entitled to summary judgment on its claim to enforce the levy. B. Is the United States entitled to a penalty? 26 U.S.C. § 6332(d)(2) provides that any per States, 896 F.2d 152 (5th Cir.1990) (<HOLDING>); Citizens & Southern, 538 F.2d 1101 (bona fide
holding that a cause of action for wrongful death is an asset of an estate holding that reasonable cause exists where meritorious wrongful levy action is instituted prior to surrender of levied property recognizing cause of action for wrongful discharge recognizing cause of action for wrongful death holding that a private right of action exists