Legal Opinion

Valley Finance, Inc. v. United States

Court of Appeals for the D.C. Circuit

Decided July 14, 1980No. Nos. 78-1585, 79-1151 and 79-1301PublishedCited by 86 opinions

1Opinion of the Court

Opinion for the Court filed by District Judge GESELL.

GESELL, District Judge:

These companion appeals were consolidated for argument with consent of counsel and will be dealt with in a single opinion. They arise from a jeopardy assessment for income taxes exceeding 4.5 million dollars made by the Internal Revenue Service (“IRS”) against one Tongsun Park on January 18, 1977. The IRS seized assets of Pacific Development, Inc. (“Pacific”), a corporation wholly owned by Park, claiming that the company was a mere alter ego of the taxpayer. Pacific, incorporated in the District of Columbia in 1968,…

2Cases cited18 opinions

  1. Fuentes v. ShevinSupreme Court of the United States · 1972
  2. Association of Data Processing Service Organizations, Inc. v. CampSupreme Court of the United States · 1970
  3. Goss v. LopezSupreme Court of the United States · 1975
  4. Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
  5. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943

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3Cited by86 opinions

  1. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  2. United States v. Jon-T Chemicals, Inc., and Lewis M. Overton, Jr., Receiver for Jon-T Chemicals, Inc.Court of Appeals for the Fifth Circuit · 1985
  3. Edith Libutti, Doing Business as Lion Crest Stable, a Sole Proprietorship v. United StatesCourt of Appeals for the Second Circuit · 1997
  4. Bowman, Jerry v. Wilson, Lieutenant Scott E., Brig Officer, Naval Confinement Facility Philadelphia Naval Yard. Appeal of Lieutenant Scott E. WilsonCourt of Appeals for the Third Circuit · 1982
  5. Towe Antique Ford Foundation, a Nonprofit Montana Corporation v. Internal Revenue Service Department of Treasury United States of AmericaCourt of Appeals for the Ninth Circuit · 1993

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