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CASH v. U.S.

No. 90-1922.

961 F.2d 562 (1992)

Robert L. CASH and Evelyn L. Cash, Plaintiff-Appellants, v. UNITED STATES of America, Defendant-Counter Plaintiff-Appellee, v. Randall C. BLOCK, Counter Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

June 1, 1992.

Attorney(s) appearing for the Case

Barnett & Cook, Clinton W. Cook and Bennett G. Cook, Lubbock, Tex., for Cash and Block.

Kenneth L. Green, Gary Allen, Chief, and Deborah Swann, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., for the U.S.

Before DAVIS, JONES, and EMILIO M. GARZA, Circuit Judges.

W. EUGENE DAVIS, Circuit Judge:

Taxpayers appeal the district court's adverse judgment. They argue that the Internal Revenue Service's levy on accounts receivable of LTS Optical, Inc. (the taxpayers' corporation) satisfied the corporation's tax liability, and thereby relieved taxpayers of any liability under § 6672 of the Internal Revenue Code. The United States challenges the taxpayers' standing to raise this claim...

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