TOWE ANTIQUE FORD FOUNDATION v. I.R.S.

No. 92-35317.

999 F.2d 1387 (1993)

TOWE ANTIQUE FORD FOUNDATION, a Nonprofit Montana Corporation, Plaintiff-Appellant, v. INTERNAL REVENUE SERVICE; Department of Treasury; United States of America, Defendants-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided July 22, 1993.


Attorney(s) appearing for the Case

Gerald Murphy, Moulton, Billingham, Longo & Mather, Billings, MT, for plaintiff-appellant; Thomas E. Towe, Towe, Ball, Enright & Mackey, Billings, MT (appearance only).

Frank P. Cihlar, U.S. Dept. of Justice, Tax Div., Washington, DC, for defendants-appellees.

Before: SKOPIL, ALARCON and BEEZER, Circuit Judges.


ALARCON, Circuit Judge:

Plaintiff-Appellant Towe Antique Ford Foundation ("TAFF"), a nonprofit charitable corporation incorporated under Montana law, appeals from the judgment in favor of the United States in this wrongful levy action brought pursuant to 26 U.S.C. § 7426.

TAFF contends that reversal is compelled because the district court erred prejudicially in making the following rulings: 1) TAFF was the alter ego of Towe; 2) the alter ego doctrine...

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