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BUSINESS TITLE CORP. v. DIV. OF LABOR LAW ENFORCEMENT

Docket No. L.A. 30558.

17 Cal.3d 878 (1976)

553 P.2d 614

132 Cal. Rptr. 454

BUSINESS TITLE CORPORATION, Plaintiff, v. DIVISION OF LABOR LAW ENFORCEMENT et al., Defendants and Appellants; UNITED STATES OF AMERICA, Defendant and Respondent.

Supreme Court of California.

September 2, 1976.

Attorney(s) appearing for the Case

COUNSEL

Lipsig, Rosenfield, Temkin & Leff, Robert G. Leff, Denison & Kightlinger, John P. Kightlinger, Evelle J. Younger, Attorney General, Thomas Scheerer and Martin Milas, Deputy Attorneys General, and Lazar, Friedman, Stahl & Jabin for Defendants and Appellants.

Edward H. Levi, United States Attorney General, Scott P. Crampton, Assistant Attorney General, Gilbert E. Andrews, Crombie J.D. Garrett, Stephen M. Gelber, William D. Keller, United States Attorney, and Charles H. Magnuson, Assistant United States Attorney, for Defendant and Respondent.

Coulter, Vernoff & Brewer and George P. Coulter as Amici Curiae.

OPINION

SULLIVAN, J.

In this interpleader action brought by an escrow holder to resolve conflicting claims to proceeds of the sale of a liquor license, various wage claimant creditors of the seller appeal from the judgment entered in favor of defendant United States of America for unpaid taxes and penalties.

On September 24, 1971, the District Director of Internal Revenue made an assessment against Mating Game, Inc. for unpaid...

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