United States Second Circuit

Plaintiff can assert no priority on behalf of his attorney's lien over the federal tax liens under 26 U.S.C. section 6323(b)(8). District court is not the proper forum for consideration of such a request for abatement of interest and penalties on defendant's unpaid taxes.

Appellate Information

• Decided 03/12/2003
• Published 03/12/2003

Judges

• SACK, Circuit Judge., Before:  SACK, KATZMANN, and B.D. PARKER, Circuit Judges.

Court

• United States Second Circuit

Counsel

• For Appellant:
  
• Glenn H. Ripa, New York, N.Y., for Appellants.


• For Appellees:
  
• Ellen Page Delsole,Tax Division, Department of Justice (Eileen J. O'Connor, Assistant Attorney General, Richard Farber, Tax Division, Department of Justice, Kathleen Mehltretter, United States Attorney, of counsel), Washington, D.C., for Appellee.