Grant Investments Fund, a Partnership v. Internal Revenue Service Department of Treasury United States of America

1 F.3d 1246 Unpublished Disposition NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. GRANT INVESTMENTS FUND, A PARTNERSHIP, Plaintiff-Appellant, v. INTERNAL REVENUE SERVICE; Department of Treasury; United States of America, Defendants-Appellees. No. 91-35994. United States Court of Appeals, Ninth Circuit. Argued and Submitted May 6, 1993. Decided July 19, 1993. Before SKOPIL, ALARCON and BEEZER, Circuit Judges. 1 MEMORANDUM * 2 Plaintiff-Appellant Grant Investments Fund ("GIF" or the "Fund") appeals from the judgment in favor of the United States in this wrongful levy action brought pursuant to 26 U.S.C. Sec. 7426 . GIF makes the following contentions in this appeal: One, the United States did not offer sufficient evidence to support a finding that Towe used GIF to perpetrate fraud; Two, the district court's finding that GIF was the alter ego of Towe was clearly erroneous; Three, the United States' seizure of GIF's property constituted a taking without compensation in…