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S & S GASKET CO., INC. v. UNITED STATES

No. 77-3274-NA-CV.

505 F.Supp. 405 (1978)

S & S GASKET COMPANY, INC. v. UNITED STATES of America.

United States District Court, M. D. Tennessee, Nashville Division.

November 9, 1978.

Attorney(s) appearing for the Case

William Richie Pigue, Glasgow, Adams, Taylor & Philbin, Nashville, Tenn., for plaintiff.

Hal Hardin, U. S. Atty., Nashville, Tenn., J. V. Crockett, III, Atty., Tax Division, Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM

MORTON, Chief Judge.

This suit is brought pursuant to 26 U.S.C. § 7426 alleging a wrongful levy to collect taxes by the United States of America. This court has jurisdiction pursuant to 28 U.S.C. § 1346. The facts are stipulated. Both plaintiff and defendant have filed motions for summary judgment.

The stipulated facts are as follows:

(1) Plaintiff is a Tennessee corporation with its principal place of business on Fiberglass...

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