In re Towe

97 F.3d 1461 78 A.F.T.R.2d 96 -6798, 97-1 USTC P 50,162 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. In re William Edward TOWE, aka Edward Towe and Cora Florence Towe, aka Florence Towe, Debtors. UNITED STATES of America, Plaintiff-Appellee, v. William Edward TOWE; Florence Cora Towe, Defendants-Appellants. No. 95-35066. United States Court of Appeals, Ninth Circuit. Submission Deferred Feb. 26, 1996. Resubmitted March 26, 1996. * Decided Sept. 23, 1996. 1 Before: FLETCHER, NOONAN, and RYMER, Circuit Judges 2 MEMORANDUM ** 3 William Edward Towe appeals the judgment of the district court denying him a discharge in bankruptcy. Upholding the district court's application of collateral estoppel, we affirm the judgment. PROCEEDINGS 4 On July 31, 1989 the United States levied on 91 antique automobiles titled in the name of Towe Antique Ford Foundation (TAFF). TAFF thereupon brought a wrongful levy action under § 7426 of the Internal Revenue Code contending that it was the…