Living Care Alternatives v. United States

OPINION

DAVID L. BUNNING, District Judge.

In these consolidated appeals, Plaintiffs-Appellants Living Care Alternatives of Kirkersville, Inc. (“Living Care Kirkersville”) and Living Care Alternatives of Utica, Inc. (“Living Care Utica”) appeal the district courts’ summary affirmances of the Internal Revenue Service (“IRS”) Appeals Officers’ administrative decisions upholding the filing of tax levy and/or lien notices against them. The Government argues the district courts properly concluded that the matters raised by Living Care Kirkersville and Living Care Utica were previously litigated in…