J. A. Wynne Co. v. R. D. Phillips Construction Co.

MEMORANDUM OPINION

GEORGE C. YOUNG, Chief Judge.

This cause came before the Court for hearing on plaintiffs’ motion for summary judgment against the United States of America, on the cross motion of the United States for summary judgment against plaintiffs, on defendant Keene’s motion for summary judgment against plaintiffs, and on the plaintiffs’ motion for default judgment against R. D. Phillips Construction Company, Inc. The cause arises under the Wrongful Levy Statute, 26 U.S.C. § 7426(a).

FACTUAL BACKGROUND

On April 1, 1976 the defendant Tenneco Oil Company entered into a written agreement…