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JFWIRS, LTD. v. UNITED STATES

Civ. A. No. 84-0549.

607 F.Supp. 566 (1985)

JFWIRS, LTD., Plaintiff, v. The UNITED STATES of America, Defendant.

United States District Court, M.D. Pennsylvania.

April 23, 1985.

Attorney(s) appearing for the Case

Richard E. Fehling, Marcia A. Binder, Stevens & Lee, Reading, Pa., for plaintiff.

James West, Asst. U.S. Atty., Harrisburg, Pa., Jefferson K. Fox, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendant.

MEMORANDUM

CALDWELL, District Judge.

I. Introduction and Background

Pending at present in this matter are cross motions for summary judgment. At issue is whether the Internal Revenue Service (IRS) may impose a levy upon a liquor license issued by the Commonwealth of Pennsylvania, and sell the same at an execution sale to satisfy a tax claim against the holder of the license.

The parties...

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