WILLIAM L. COMER FAMILY EQUITY TRUST v. U.S.

No. 87-CV-30092 PH.

732 F.Supp. 755 (1990)

WILLIAM L. COMER FAMILY EQUITY TRUST, Myra L. Comer, Trustee; American Way Trust, Myra L. Comer, Trustee; Financial Freedom Consultants, William L. Comer, Trustee; OSA Development Company with OSA Explorations as General Partner, William L. Comer, Trustee; Burica Development Company, with Burica Explorations as General Partner, William Comer, Trustee, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Michigan, S.D.

February 16, 1990.


Attorney(s) appearing for the Case

Peter C. Jensen, Saginaw, Mich., for plaintiffs.

Michael Hluchaniuk, Bay City, Mich., Tom Clark, Tax Div., Justice Dept., Washington, D.C., for defendant.


FINDINGS OF FACT AND CONCLUSIONS OF LAW

JAMES HARVEY, District Judge.

This is a wrongful levy action brought pursuant to 26 U.S.C. § 7426. The plaintiffs assert that the Internal Revenue Service (IRS), in attempting satisfaction of income tax deficiencies owed by William L. and Myra Comer, levied against property owned by the plaintiffs. The government, conversely, contends that the plaintiffs are merely...

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