MEMORANDUM
TROUTMAN, District Judge.
Plaintiff, taxpayer, filed this action, seeking a refund of $11,951.84 which was in plaintiff's bank account and levied upon by defendant for failure to pay the federal withholding taxes allegedly owed by the Lakewood Summer Playhouse in Tamaqua, Pennsylvania. The relevant facts are as follows: In 1965, plaintiff advanced to one Charles W. Hall, Jr. [Hall] $19,197.56 to help finance said theater, which went out of business...
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