Legal Opinion
Towe Antique Ford Foundation, a Nonprofit Montana Corporation v. Internal Revenue Service Department of Treasury United States of America
Court of Appeals for the Ninth Circuit
Decided July 22, 1993No. 92-35317PublishedCited by 103 opinions
1Opinion of the Court
ALARCON, Circuit Judge:
Plaintiff-Appellant Towe Antique Ford Foundation (“TAFF”), a nonprofit charitable corporation incorporated under Montana law, appeals from the judgment in favor of the United States in this wrongful levy action brought pursuant to 26 U.S.C. § 7426.
TAFF contends that reversal is compelled because the district court erred prejudicially in making the following rulings: 1) TAFF was the alter ego of Towe; 2) the alter ego doctrine was applicable although the Government did not offer any evidence to support a finding that Towe used TAFF to perpetrate fraud; 3) TAFF’s…
2Cases cited16 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Lois Anderson v. United StatesCourt of Appeals for the Ninth Circuit · 1992
- Valley Finance, Inc. v. United StatesCourt of Appeals for the D.C. Circuit · 1980
- Shades Ridge Holding Company, Inc. v. United States of America, United States of America v. Sam A. Fiorella and Shades Ridge Holding Company, Inc.Court of Appeals for the Eleventh Circuit · 1989
- James Adams v. Johns-Manville Corporation, and Raymark Industries, Inc.Court of Appeals for the Ninth Circuit · 1989
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3Cited by103 opinions
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- Edith Libutti, Doing Business as Lion Crest Stable, a Sole Proprietorship v. United StatesCourt of Appeals for the Second Circuit · 1997
- Eastern Trading Company v. Refco, Inc., and Refco Capital CorporationCourt of Appeals for the Seventh Circuit · 2000
- LFC Marketing Group, Inc. v. LoomisNevada Supreme Court · 2000
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