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O'HARE v. U.S.

No. 87-2107.

878 F.2d 953 (1989)

Edward J. O'HARE, Plaintiff, v. UNITED STATES of America, Defendant, Third-Party Plaintiff-Appellee, Commercial Credit Business Loans, Inc., Third-Party Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided July 10, 1989.

Attorney(s) appearing for the Case

Melanie LaFave (argued), Jaffe, Snider, Raitt & Heuer, P.C., Detroit, Mich., for third-party defendant-appellant.

Ellen Christensen, Asst. U.S. Atty., Detroit, Mich., Gary R. Allen (lead counsel), William S. Rose, Jr., Tax Div., Dept. of Justice, Washington, D.C., Wynette J. Hewett, James H. Love (argued), Chicago, Ill., for defendant, third-party plaintiff-appellee.

Before MARTIN and BOGGS, Circuit Judges; and CONTIE, Senior Circuit Judge.

CONTIE, Senior Circuit Judge.

Commercial Credit Business Loans, Inc. (CCBL) appeals from the district court's entry of judgment in accordance with a jury verdict in favor of the United States in this civil action brought pursuant to IRC § 3505. For the following reasons, we affirm the district court's judgment.

I.

On December 1, 1975, Hope Picture Frame Company entered into a financing agreement with CCBL, a commercial finance company. CCBL...

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