Opinion
Case No.: 2:06-900-CWH.
April 3, 2006
ORDER
On March 20, 2006, the plaintiff commenced this action seeking to prevent the Internal Revenue Service ("IRS") from collecting an alleged tax liability through a levy of an escrow account in which the defendant, Pratt-Thomas Gumb, P.A. ("Pratt-Thomas"), is the escrow agent. On March 31, 2006, Pratt-Thomas answered and filed a cross-claim against the IRS and a third-party action against Charles A. Atkins.
Pratt-Thomas claims no ownership in the money held in the escrow account. Pratt-Thomas alleges that as of March 31, 2006, the amount held in the escrow account totaled $2,657,005.58. On March 31, 2006, Pratt-Thomas deposited the entire escrow amount with the Clerk. Pursuant to Rule 22 of the Federal Rules of Civil Procedure and Local Rule 67.01(A), the Clerk is directed to place the entire amount in dispute, $2,657,005.58, in an interest bearing account and hold the same until further order of the Court.
AND IT IS SO ORDERED.