United States First Circuit

In interpleader action filed by bank to determine who had the right to the surplus proceeds remaining following foreclosure on, and sale of, undeveloped lots to pay the outstanding mortgage, summary judgment awarding the United States the funds is affirmed, where: 1) a company that owned a particular parcel of land was the "nominee," or alter ego, of a delinquent taxpayer for purposes of a federal tax lien that attached to all of the taxpayer's property; and thus, 2) the funds remaining were properly awarded to the United States for assessments for the individual taxpayer's unpaid federal income tax liabilities and federal tax lien.

Appellate Information

• Decided 01/11/2013
• Published 01/11/2013

Judges

• STAHL

Court

• United States First Circuit

Counsel