No. 74-1436.

514 F.2d 935 (1975)

G. M. LEASING CORP., Plaintiff-Appellee, v. The UNITED STATES of America et al., Defendants-Appellants, George I. Norman, III, Intervenor.

United States Court of Appeals, Tenth Circuit.

Decided May 1, 1975.

Rehearing Denied June 17, 1975.

Attorney(s) appearing for the Case

Murray S. Horwitz, Tax Div. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews and Murray S. Horwitz, Attys., Tax Div., Dept. of Justice), Washington, D. C., for defendants-appellants.

Richard J. Leedy, Salt Lake City, Utah, for plaintiff-appellee.

Before HILL, SETH and BARRETT, Circuit Judges.

HILL, Circuit Judge.

This appeal results from an allegedly wrongful levy and seizure by Internal Revenue Service agents of a corporation's assets to satisfy the income tax liability of an individual taxpayer.

Appellants are the United States, Department of the Treasury, Internal Revenue Service (IRS), and a district director and several agents of the IRS. Appellee G. M. Leasing Corp. is a Utah corporation allegedly engaged in a luxury car leasing business...

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