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LIVING CARE ALTERNATIVES OF UTICA, INC. v. U.S.

No. 04-3194, 04-3554.

411 F.3d 621 (2005)

LIVING CARE ALTERNATIVES OF UTICA, INC., Plaintiff-Appellant, v. UNITED STATES of America, Internal Revenue Service, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: June 2, 2005.

Attorney(s) appearing for the Case

Carla I. Struble, Westerville, Ohio, for Appellant.

Robert J. Branman, United States Department of Justice, Appellate Section, Tax Division, Washington, D.C., for Appellee.

Rachel I. Wollitzer, Jonathan S. Cohen, United States Department of Justice, Appellate Section, Tax Division, Washington, D.C., for Appellee.

Before: KEITH, MERRITT, and CLAY, Circuit Judges.

OPINION

MERRITT, Circuit Judge.

This opinion addresses separate appeals from two district court cases involving the same parties and almost identical issues. Plaintiff, Living Care Alternatives of Utica, Inc. ("Living Care"), appeals district court decisions affirming the Internal Revenue Service's Appeals Office decisions to allow tax liens and levies on Living Care's property for unpaid employment taxes for various periods between 1995 and 2001. These...

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