Court of Appeals for the Ninth Circuit October 24, 1995, 94-55316 (Supermail Cargo, Inc. v. United States)

REINHARDT, Circuit Judge:

In this case, the Internal Revenue Service (“IRS”) levied upon funds due to a company without notifying the company that it had done so. The debt that the IRS was attempting; to collect was owed by the company’s former lawyers, not the company, as the IRS knew. In fact, the company owed no money to the IRS at all.