Clark v. United States
Court of Appeals for the First Circuit
1Opinion of the Court
STAHL, Circuit Judge.
In this federal income tax case, the government appeals the district court’s grant of summary judgment to taxpayer Grenville Clark III in his suit to recover monies collected by the Internal Revenue Service (“IRS”) by levy. Although we agree with the district court that summary judgment for the taxpayer was appropriate, we reduce the amount of the judgment because the district court erred in finding that Clark had fully extinguished his 1985 tax liability.
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Factual Background
The material facts are not in dispute. On August 14, 1986, Clark and his then-spouse, Marguerite…
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