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WILLIAMS v. U.S.

No. 92-56207.

24 F.3d 1143 (1994)

Lori Rabin WILLIAMS, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 19, 1994.

Attorney(s) appearing for the Case

Philip Garrett Panitz, Gose, Panitz & Lechman, Camarillo, CA, for plaintiff-appellant.

Kevin M. Brown, U.S. Dept. of Justice, Washington, DC, for defendant-appellee.

Before: PREGERSON, O'SCANNLAIN, and FERNANDEZ, Circuit Judges.

Opinion by Judge O'SCANNLAIN

O'SCANNLAIN, Circuit Judge:

We must decide whether one who erroneously pays the taxes of another may sue for a refund.

I

In April 1975, Jerrold Rabin ("Rabin") and his then wife Lori Rabin (now Lori Williams) ("Williams") purchased a house in Pacific Palisades, California. On June 29, 1987, and March 28, 1988, the government assessed employment tax liabilities against Rabin. On October 20, 1988, Rabin transferred...

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