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U.S. v. GENERAL MOTORS CORP.

No. 89-1423.

929 F.2d 249 (1991)

UNITED STATES of America, Plaintiff-Appellee, v. GENERAL MOTORS CORPORATION, Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided April 1, 1991.

Attorney(s) appearing for the Case

Robert L. Baker, Buck & Baker, Nashville, Tenn., Geneva S. Halliday, Asst. U.S. Atty., Office of U.S. Atty., Detroit, Mich., Gary R. Allen, Acting Chief, David E. Brunori, William S. Estabrook, Brian C. Griffin (argued), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, D.C., for plaintiff-appellee.

Daniel M. Share (argued), Barris, Sott, Denn & Driker, Victor S. Valenti, Detroit, Mich., for defendant-appellant.

Before RYAN and NORRIS, Circuit Judges, and ALLEN, Senior District Judge.

RYAN, Circuit Judge.

The government filed this action against General Motors Corporation ("GM"), pursuant to 26 U.S.C. § 6332(c), alleging that GM failed to honor an Internal Revenue Service ("IRS") levy upon property in its possession that belonged to another taxpayer and was encumbered by federal tax liens. The district court entered summary judgment for the government. We are asked to decide whether, as the district court held, GM is liable under I.R.C. &...

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