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SHADES RIDGE HOLDING CO., INC. v. U.S.

No. 88-7085.

880 F.2d 342 (1989)

SHADES RIDGE HOLDING COMPANY, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. UNITED STATES of America, Plaintiff-Appellee. v. Sam A. FIORELLA and Shades Ridge Holding Company, Inc., Defendants-Appellants.

United States Court of Appeals, Eleventh Circuit.

Rehearing Denied September 29, 1989.

As Amended October 26, 1989.

Attorney(s) appearing for the Case

Vowell, Meelheim & McKay, PC, Richard A. Meelheim, Samuel R. McCord, Birmingham, Ala., for plaintiff-appellant.

Frank W. Donaldson, U.S. Atty., Caryl Privett, Asst. U.S. Atty., Birmingham, Ala., Gary R. Allen, Chief, Appellate Sec., William Rose, Jr., Joan Oppenheimer, William Estabrook, Asst. Attys. Gen., Appellate Section, U.S. Dept. of Justice, Washington, D.C., for U.S.

Before RONEY, Chief Judge, COX, Circuit Judge, and MORGAN, Senior Circuit Judge.

RONEY, Chief Judge:

This appeal arises from two consolidated cases: a quiet title action commenced by Shades Ridge Holding Company, Inc. (Shades Ridge) and a foreclosure action by the Government to foreclose tax liens and judgment liens relating to the tax liability of Sam Fiorella against property titled to Shades Ridge. The district court entered a decree of foreclosure against three parcels of real property, holding that Shades Ridge was the alter ego and fraudulent...

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