Today's Child Learning Center Inc. v. United States

FINDINGS OF FACT AND CONCLUSIONS OF LAW

NEWCOMER, District Judge.

This is a case in which plaintiff seeks a retiren of $18,152.56 from the United States government, claiming wrongful levy under 26 U.S.C. § 7426. The Unites States asserts that plaintiff, as the alter ego or successor in interest to the taxpayer, was correctly assessed the tax. After a bench trial of this case on February 19, 1998, and after considering all the evidence of record and the arguments of counsel, the Court makes the following findings of fact and conclusions of law.

I.FINDINGS OF FACT 1

1. On October 20, 1988, an…