Oxford Capital Corp. v. United States

This is an appeal from the decision of a magistrate judge that a levy imposed by the Internal Revenue Service (“IRS”) on bank accounts of Oxford Capital Corporation (“Oxford”) to satisfy tax liabilities of one of its subsidiaries was not a wrongful levy under 26 U.S.C. § 7426. Oxford filed this appeal, contending that the magistrate judge erred both in its application of the applicable standard and in its factual findings. For the reasons discussed, we vacate the decision of the magistrate judge and remand for further proceedings consistent with this opinion.

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Oxford is a publicly-traded…