MEMORANDUM and ORDER
DAVID W. WILLIAMS, District Judge.
Taxpayer-Bankrupt-Appellee Resthaven Psychiatric Hospital ("RPH") accumulated unpaid withholding taxes in 1975. Due to its failure to pay over such taxes to the Appellant United States, it was assessed in excess of $190,000, and ultimately the Internal Revenue Service ("IRS") levied on and seized the real property of RPH at 765 College Street in Los Angeles on April 16, 1976. On May 24, 1976, RPH was...
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