Legal Opinion
Hoye v. United States
District Court, S.D. California
Decided December 11, 1958No. Civ. No. 1065-57PublishedCited by 2 opinions
1Opinion of the Court
TOLIN, District Judge.
This action arises under the Internal Revenue Code, 26 U.S.C.A., and involves the right of the United States to proceed against a municipal corporation as an employer for the collection of unpaid revenues owed by a delinquent taxpayer who is also an employee of the municipal corporation.
The United States, not needing the aid of court procedure in such a circumstance, served a notice of levy and final demand upon the City of Los Angeles as the employer of a delinquent taxpayer for accrued wages due and owing by the city. In order to prohibit such action, the Controller of…
2Cases cited3 opinions
- Florida v. MellonSupreme Court of the United States · 1927
- United States v. Edward I. Eiland, Trustee in Bankruptcy of Sport Coal Company, Inc., a Corporation, BankruptCourt of Appeals for the Fourth Circuit · 1955
- Bank of Nevada v. United StatesCourt of Appeals for the Ninth Circuit · 1958
3Cited by2 opinions
- Brown v. Ford Motor Co.Ohio Court of Appeals · 2003
- Feagle v. FeagleDistrict Court of Appeal of Florida · 1988