proper levy there was nothing wrong like it was a proper and legal levy there was no they never can because you lose the you don't have the right to move or change the money around the sixty three thirty two in the regs and the code the government has to release the money back to the taxpayer and i understand the government hasn't i got rid of their lea tax liability the time that the overpaying occurred was february of two thousand and two some six years after that levy actually occurred until until that time the taxpayers  right to protest sue and receive that money and the government did apparently would have had the right to sue the bank or complain if they didn't get the money if they didn't do anything letter i understand that and so it's what's replaced if the if they are us never got the money of course records devoid of you know how they want to know how they handle that these and what happened in this particular case but it's that they have a creditor relationship between the vatican the internal property like money to which they have legal title even if somebody else has a lien on the property or some security interest in it that would block the property in some way you know all due respect your commerce also in the case of the government is in constructive possession of the funds upon the levy i don't think there's any dispute in the case there's the case to say that's provisional because since since the government only steps into the shoes  taxpayer if there's a superior right to the clients by some other party can raise a claim that you know our rights period so the i r s has but no one's raised any sort of claims in this particular case i think that you know it's defense to that the turnover orders from the bankruptcy court is the government trying to get this money from first interstate now wells fargo did it and so i tried to get the money to my knowledge s as well to that so why can't the iris now go to the bank and say look we have this levy it's out of this person's account we never got the money you owe us the money we don't know if the funds have been put into some transfer account in the bank you know where they collect all these kinds of things or put in some other person's account or paid to the government or paid to someone else but we do know the taxpayer doesn't have there's no possibility this issue can be resolved by a mediation court because it's sort of a zero sum game constructive possession and they're using these third party cases to defend their position they're using cases where a third party is claiming a superior right to the funds as a reason why they should be charged with receipt of this money in this case there was no third parties records i don't know what proof from ferris would have that legally they still have a right to collect that those funds because there's no one claimant ownership over those and they're trying to avoid or ship is what they're trying to do with the difficult the year is we don't know if it's a problem creature relationship between the bank and the government after the twenty first the raid say that the bank must turn over the funds to the i r s well that's the obligation that was breached in this situation but i don't see that