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UNITED STATES v. CITY OF LOS ANGELES

Civ. No. 70-2860.

336 F.Supp. 1014 (1972)

UNITED STATES of America, Plaintiff, v. CITY OF LOS ANGELES, California, Defendant and Counterclaimant, v. STATE OF CALIFORNIA, FRANCHISE TAX BOARD, Defendant to Counterclaim.

United States District Court, C. D. California.

January 18, 1972.

Attorney(s) appearing for the Case

Robert L. Meyer, U. S. Atty., Charles H. Magnuson, Asst. U. S. Atty., Chief, Tax Division, and Lawrence V. Brookes, Asst. U. S. Atty., Los Angeles, Cal., for plaintiff.

Roger Arneberg, City Atty., John A. Daly, Asst. City Atty., and Ronald Tuller, Deputy City Atty., Los Angeles, Cal., for defendant and counterclaimant.

Evelle J. Younger, Atty. Gen., State of Cal., Philip C. Griffin and Mark W. Jordan, Deputy Attys. Gen., for defendant to counterclaim.

DECISION, FINDINGS OF FACT AND CONCLUSIONS OF LAW, AND ORDER FOR JUDGMENT FOR PLAINTIFF

HAUK, District Judge.

This is an action for enforcement of Internal Revenue levy and for collection of Internal Revenue taxes for failure to honor levy. Jurisdiction is conferred upon this Court by 28 U.S.C. Sections 1340 and 1345 and 26 U.S.C. Section 7402. The specific question posed is whether a tax lien of the United States, hereafter the Government, perfected prior...

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