United States Sixth Circuit

In an action to quiet title after an IRS seizure, judgment in favor of defendant is affirmed on grounds that subject matter jurisdiction was proper and the Internal Revenue Code allows for substantial, rather than literal, compliance with regulations regarding tax-seizure notification.

Appellate Information

• Argued 03/09/2004
• Decided 07/27/2004
• Published 07/27/2004

Judges

• Before: BOGGS, Chief Judge;  DAUGHTREY, Circuit Judge;  and ALDRICH, District Judge.

Court

• United States Sixth Circuit

Counsel

• For Appellant:
  
• Charles E. McFarland (argued and briefed), Campbellsburg, KY, for Plaintiff-Appellant.


• For Appellees:
  
• Michael C. Walton (argued and briefed), Rhoades, McKee, Boer, Goodrich & Titta, Grand Rapids, MI, for Third Party-Appellee.