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PHELPS v. UNITED STATES

No. 74-121.

421 U. S. 330 (1975)

PHELPS, RECEIVER IN BANKRUPTCY v. UNITED STATES.

Supreme Court of United States.

Decided May 19, 1975.

Attorney(s) appearing for the Case

Dennis E. Quaid argued the cause for petitioner. With him on the briefs were Kevin J. Gillogly and Daniel C. Ahern.

Keith A. Jones argued the cause for the United States. With him on the brief were Solicitor General Bork, Assistant Attorney General Crampton, and Crombie J. D. Garrett.

MR. JUSTICE BRENNAN delivered the opinion of the Court.

Between March and June 1971 the Internal Revenue Service (IRS) made assessments of federal taxes in the amount of $140,831.59 against Chicagoland Ideel Cleaners, Inc. Chicagoland failed to pay the taxes after formal demand. Instead, on June 28, 1971, Chicagoland transferred its assets to an assignee for the benefit of creditors. The assignee promptly converted the assets into cash of approximately $38,000. On...

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