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WESTGATE-CALIFORNIA CORPORATION v. UNITED STATES

No. 73-3219.

496 F.2d 839 (1974)

WESTGATE-CALIFORNIA CORPORATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

April 10, 1974.

Attorney(s) appearing for the Case

Herbert L. Moody (argued), Tax Div. Dept. of Justice, Washington, D. C., Harry D. Steward, U. S. Atty., Robert Filsinger, Asst. U. S. Atty., San Diego, Cal., for defendant-appellant.

Ralph K. Kessler (argued), Mudge, Rose, Guthrie & Alexander, New York City, Friedman, Heffner, Kahn, & Dysart, San Diego, Cal., for plaintiff-appellee.

Charles P. Scully, San Francisco, Cal., amicus curiae for Cal. State Federation of Labor, AFL-CIO.

Before MERRILL, KOELSCH and DUNIWAY, Circuit Judges.

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 Westgate-California 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...

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