Garcia v. Island Program Designer, Inc.

OPINION AND ORDER

GIERBOLINI, Senior District Judge.

I. Introduction and Facts

Island Program Designer, Inc. (IPD) was a health service organization under Puerto Rico law. IPD made a statutory deposit of $100,000.00 with the Treasury Department of the Commonwealth of Puerto Rico, as required by law. IPD became insolvent and the Superior Court of Puerto Rico entered an order for liquidation of IPD’s assets. The Final Report of the Administrator-Liquidator of IPD indicates that IPD’s assets are comprised of what remains of the $100,000.00 statutory deposit.

The U.S. Internal Revenue Service moved…