United States v. General Motors Corporation
Court of Appeals for the Sixth Circuit
1Opinion of the Court
RYAN, Circuit Judge.
The government filed this action against General Motors Corporation (“GM”), pursuant to 26 U.S.C. § 6332(c), alleging that GM failed to honor an Internal Revenue Service (“IRS”) levy upon property in its possession that belonged to another taxpayer and was encumbered by federal tax liens. The district court entered summary judgment for the government. We are asked to decide whether, as the district court held, GM is liable under I.R.C. § 6332(d)(1) for failing to honor the levy. We conclude that it is not.
Specifically, we hold that the district court erred in granting the…
2Cases cited10 opinions
- Aquilino v. United StatesSupreme Court of the United States · 1960
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- United States v. Morris WeintraubCourt of Appeals for the Sixth Circuit · 1979
- United States v. Bank of CelinaCourt of Appeals for the Sixth Circuit · 1983
- The State Bank of Fraser, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Sixth Circuit · 1988
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