Elias Kaggen and Rio A. Sferrazza v. Internal Revenue Service and United States of America
Court of Appeals for the Second Circuit
1Opinion of the Court
FRANK A KAUFMAN, District Judge:
I
On June 6, 1995, this Court affirmed the judgment of the United States District Court for the Eastern District of New York (Spatt, J.), granting to defendants summary judgment. Kaggen v. I.R.S., 57 F.3d 163, 165 (2d Cir.1995). Plaintiff taxpayers sought thereafter a rehearing which this Court has granted. After such rehearing, this Court hereby reconfirms its earlier decision.
This case concerns the propriety of an Internal Revenue Service (“IRS”) levy against taxpayers’ bank accounts to satisfy a tax deficiency. The issue is whether notice given to taxpayers…
2Cases cited6 opinions
- Texas & Pacific Railway Co. v. PottorffSupreme Court of the United States · 1934
- United States v. Vincent J. Ricciardi, United States of America v. Stanley M. UngerCourt of Appeals for the Second Circuit · 1966
- Jack Harold Halfen v. United StatesCourt of Appeals for the Tenth Circuit · 1963
- United States v. Algylee Bobbe WilsonCourt of Appeals for the Third Circuit · 1971
- United States v. Joseph MauroCourt of Appeals for the Second Circuit · 1974
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- Klingshirn v. United States (In Re Klingshirn)Bankruptcy Appellate Panel of the Sixth Circuit · 1997
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