WOLFE v. UNITED STATES

No. 85-4027.

798 F.2d 1241 (1986)

Charles E. WOLFE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Submitted July 9, 1986.

Decided August 29, 1986.


Attorney(s) appearing for the Case

Jack W. Burnett, Billings, Mont., for plaintiff-appellant.

Richard Driscoll, Dept. of Justice, Washington, D.C., for defendant-appellee.

Before CHAMBERS and CHOY, Senior Circuit Judges, and NORRIS, Circuit Judge.


CHOY, Senior Circuit Judge:

Charles E. Wolfe appeals the district court grant of summary judgment, requiring Wolfe, as the alter ego of his corporation (Wolfe & Company), to pay taxes assessed against the corporation. The court additionally held that procedures employed by the Government to levy Wolfe's property were in compliance with federal tax statutes and regulations. We affirm.

I

BACKGROUND

Wolfe was the sole shareholder and president...

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