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UNITED STATES v. EQUITABLE LIFE ASSUR. CO. OF U. S.

No. 75 Civ. 2198.

442 F.Supp. 500 (1977)

UNITED STATES of America, Plaintiff, v. EQUITABLE LIFE ASSURANCE CO. OF the UNITED STATES, Defendant.

United States District Court, S. D. New York.

December 30, 1977.

Attorney(s) appearing for the Case

Robert B. Fiske, U. S. Atty. for the Southern District of New York, New York City, by William Roche Bronner, Asst. U. S. Atty., New York City, for plaintiff.

Werner Weinstock, New York City, by Michael W. Brody, Robert L. Rose, Robert J. Miller, New York City, for defendant.

OPINION UPON RECONSIDERATION

GRIESA, District Judge.

I

This is a tax collection action brought pursuant to Sections 6332(c)(1) and 7401 of the Internal Revenue Code of 1954, as amended, 26 U.S.C. §§ 6332(c)(1), 7401. The Government claims that Equitable failed to honor a levy pursuant to Section 6332(b) of the Code, 26 U.S.C. § 6332(b), upon the interest of a taxpayer in his life...

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