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SUPERMAIL CARGO, INC. v. U.S.

No. 94-55316.

68 F.3d 1204 (1995)

SUPERMAIL CARGO, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided October 24, 1995.

Attorney(s) appearing for the Case

Michael P. Maxwell, Los Angeles, California, for plaintiff-appellant.

Janet A. Bradley, Tax Div., Appellate Section, United States Department of Justice, Washington, DC, for defendant-appellee.

Before: BROWNING, NORRIS, and REINHARDT, Circuit Judges.

REINHARDT, Circuit Judge:

In this case, the Internal Revenue Service ("IRS") levied upon funds due to a company without notifying the company that it had done so. The debt that the IRS was attempting to collect was owed by the company's former lawyers, not the company, as the IRS knew. In fact, the company owed no money to the IRS at all. When the company finally discovered what had happened to its funds and tried to file a request, the IRS first ignored its efforts...

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