Smith v. Eggar

655 F.2d 181 81-2 USTC P 9646 C. Arnholt SMITH, British Columbia Investment Company and Westward Realty Company, Plaintiffs-Appellees, v. Roscoe L. EGGAR, Commissioner of Internal Revenue, and William H. Connett, District Director of Internal Revenue, Defendants-Appellants. No. 74-1149. United States Court of Appeals, Ninth Circuit. Originally Argued and Submitted on Aug. 5, 1975. Resubmitted After Two Intervening Remands Sept. 14, 1979. Decided Aug. 31, 1981. AS Corrected Sept. 16, 1981. Robert E. Lindsay, Washington, D. C., for defendants-appellants. Thomas Sheridan, Simon, Sheridan, Murphy, Thornton & Hinerfeld, Los Angeles, Cal., for plaintiffs-appellees. Appeal from the United States District Court for the Southern District of California. Before CHAMBERS and GOODWIN, Circuit Judges and TAYLOR, District Judge. * CHAMBERS, Circuit Judge: 1 On August 1, 1973, the Internal Revenue Service filed a jeopardy assessment in excess of twenty-two million dollars, for the single tax year of 1969, against C. Arnholt Smith. Two days later, specific and general levies were served on many persons and entities, including one on the United States National Bank (hereafter "the Bank"),…