S & S Gasket Co. v. United States

MEMORANDUM

MORTON, Chief Judge.

This suit is brought pursuant to 26 U.S.C. § 7426 alleging a wrongful levy to collect taxes by the United States of America. This court has jurisdiction pursuant to 28 U.S.C. § 1346. The facts are stipulated. Both plaintiff and defendant have filed motions for summary judgment.

The stipulated facts are as follows:(1) Plaintiff is a Tennessee corporation with its principal place of business on Fiberglass Drive, Wilson County, Tennessee.(2) Defendant is the United States of America.(3) On December 18, 1975, a final judgment was entered in the Circuit Court of…