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UNITED STATES v. PRYATELY

Nos. 17901-17903.

393 F.2d 129 (1968)

UNITED STATES of America, Plaintiff-Appellee, v. Rudy PRYATELY, Defendant-Appellant. UNITED STATES of America, Plaintiff-Appellee, v. Michael TAVONE, Defendant-Appellant. UNITED STATES of America, Plaintiff-Appellee, v. Joseph RIZZO, Defendant-Appellant.

United States Court of Appeals Sixth Circuit.

April 13, 1968.

Attorney(s) appearing for the Case

Rudy Pryately, in pro per.

Michael Tavone, in pro per.

Joseph Rizzo, in pro per.

Karl Schmeidler, Department of Justice, Washington, D. C., Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Crombie J. D. Garrett, Attys., Department of Justice, Washington, D. C., on brief; Merle M. McCurdy, U. S. Atty., Dominic J. Cimino, Asst. U. S. Atty., Cleveland, Ohio, of counsel, for appellee.

Before O'SULLIVAN, PHILLIPS and EDWARDS, Circuit Judges.

PHILLIPS, Circuit Judge.

This action was filed in the District Court by the United States to foreclose federal tax liens for withholding and unemployment taxes against appellants, Joseph Rizzo, Rudy Pryately and Michael Tavone, doing business as General Equipment Company, a partnership. The District Court appointed a receiver to preserve the seized assets of the partnership.

1) Partial summary judgment proceedings

On March 8, 1967, the District Court...

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