UNITED STATES v. ASSOCIATES COMMERCIAL CORP.

Nos. 83-1039, 83-1133.

721 F.2d 1094 (1983)

UNITED STATES of America, Plaintiff-Appellant, Cross-Appellee, v. ASSOCIATES COMMERCIAL CORPORATION, Defendant-Appellee, Cross-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided November 15, 1983.


Attorney(s) appearing for the Case

Melvin E. Clark, Jr., Tax Div., Dept. of Justice, Washington, D.C., for plaintiff-appellant, cross-appellee.

Eugene I. Meyers, Senior Vice President & Senior Tax Counsel, Steven J. Gombinski, Associate Tax Counsel, Gulf & Western Industries, Inc., New York City, Mark Lieberman, Sr. Atty., Associates Commercial Corp., Chicago, Ill., for defendant-appellee, cross-appellant.

Before CUMMINGS, Chief Judge, BAUER and FLAUM, Circuit Judges.


CUMMINGS, Chief Judge.

The United States sued Associates Commercial Corporation (Associates) for unpaid withholding tax liabilities of Dot Engravers, Inc. (Dot) pursuant to Section 3505(b)1 of the Internal Revenue Code of 1954. Associates filed a motion to dismiss the government's suit or for summary judgment on two grounds: (1) it had not been given notice of two assessments against Dot as allegedly...

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