Legal Opinion
Westgate-California Corporation v. United States
Court of Appeals for the Ninth Circuit
Decided April 10, 1974No. 73-3219PublishedCited by 15 opinions
1Opinion of the Court
OPINION
DUNIWAY, Circuit Judge:
On October 19, 1973, the Internal Revenue Service (IRS) acting under 26 U. S.C. § 6861, levied a $4,200,000 jeopardy assessment against appellee WestgateCalifornia Corporation (Westgate), covering Westgate’s alleged liability for federal income taxes for the tax periods 1963-67, 1969 and 1970. On October 23, 1973, the IRS filed notices of federal tax liens in several California and Oregon counties where Westgate’s properties and assets are located.
After unsuccessful negotiations between the parties, Westgate filed this action on November 15, 1973, seeking to…
2Cases cited11 opinions
- Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
- Miller v. Standard Nut Margarine Co. of Fla.Supreme Court of the United States · 1932
- Botta v. ScanlonCourt of Appeals for the Second Circuit · 1963
- Schreck v. United StatesDistrict Court, D. Maryland · 1969
- E. C. Lloyd v. George D. Patterson, District Director of Internal Revenue, District of AlabamaCourt of Appeals for the Fifth Circuit · 1957
6 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- United States v. MarshallCourt of Appeals for the Ninth Circuit · 1975
- Philadelphia & Reading Corporation v. United StatesCourt of Appeals for the Third Circuit · 1991
- In The Matter Of The Tax Indebtedness Of Dell W. CarlsonCourt of Appeals for the Tenth Circuit · 1978
- Carol Smith Shannon v. United StatesCourt of Appeals for the Ninth Circuit · 1975
- Harry Schildcrout v. Robert M. McKeever District Director, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1978
10 more not listed; retrieve them via the Exa API.