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Living Care Alternatives of Utica, Inc. v. United States

411 F.3d 621 (2005)

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Living Care Alternatives of Utica, Inc. v. United States

United States Court of Appeals for the Sixth Circuit
411 F.3d 621 (2005)

  • Written by Heather Whittemore, JD

Facts

Living Care Alternatives of Utica, Inc. (Living Care) (plaintiff) was a nursing home. Living Care failed to pay payroll taxes that it withheld from employees’ paychecks and owed approximately $450,000. The Internal Revenue Service (IRS) sent Living Care a notice of tax liens and an intent to levy Living Care’s property. Living Care requested a collection due-process hearing. The appeals officers concluded that the IRS could levy Living Care’s property. Living Care appealed.

Rule of Law

Issue

Holding and Reasoning (Merritt, J.)

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