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FRIERDICH v. U.S.

No. 92-1623.

985 F.2d 379 (1993)

Michael V. FRIERDICH, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 11, 1993.

Attorney(s) appearing for the Case

Ronald D. Stanley, Columbia, IL (argued), for plaintiff-appellant.

Robert L. Simpkins, Asst. U.S. Atty., Office of U.S. Atty., Criminal Div., Fairview Heights, IL, Gary R. Allen, Jordan L. Glickstein (argued), William S. Estabrook, Mark Winer, Gerald H. Parshall, Jr., Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for defendant-appellee.

Before POSNER, FLAUM, and ROVNER, Circuit Judges.

POSNER, Circuit Judge.

Michael Frierdich brought this suit against the United States contending that it had made a wrongful levy on property that Frierdich had "an interest in or lien on," 26 U.S.C. § 7426(a)(1), and seeking a judgment for some $37,000, which he claimed to be the value of his interest. 26 U.S.C. § 7426(b)(2)(B). After a bench trial, the district judge dismissed the suit on the ground that the interest claimed by Frierdich in the property...

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