UNITED STATES v. PITTMAN

No. 18652.

449 F.2d 623 (1971)

UNITED STATES of America, Plaintiff-Appellee, v. Homer PITTMAN, Helen Jakob, Defendants-Appellants, and L. C. Christensen et al., Defendants.

United States Court of Appeals, Seventh Circuit.

September 24, 1971.


Attorney(s) appearing for the Case

Gerald T. Flynn, Racine, Wis., for defendants Homer Pittman and Helen Jakob; Thomas G. Hetzel, Racine, Wis., of counsel.

Johnnie M. Walters, Asst. Atty. Gen., Tax Div., Stephen Schwarz, Atty., U. S. Dept. of Justice, Washington, D. C., David J. Cannon, U. S. Atty., Milwaukee, Wis., Meyer Rothwacks, Bennet N. Hollander, Attys., Tax Div., Dept. of Justice, Washington, D. C., for plaintiff-appellee; Joseph P. Stadtmueller, Asst. U. S. Atty., of counsel.

Before KNOCH, Senior Circuit Judge, and CUMMINGS and PELL, Circuit Judges.


PELL, Circuit Judge.

The United States brought this action to foreclose federal tax liens against six parcels of real estate allegedly owned by the taxpayer Homer Pittman.1 The district court ordered the liens foreclosed and the property sold to satisfy the tax claim. The taxpayer appeals contending that the tax has been satisfied by a prior levy on one of the six parcels. The issue presented...

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