United States Ninth Circuit

In a third party challenge by title insurers to a tax assessment and lien on an earlier owner's property, dismissal of the suit is affirmed where 28 U.S.C. section 2476 did not provide jurisdiction for the challenge to the IRS assessment of the value of the previous owner's business.

Appellate Information

• Decided 03/27/2008
• Published 03/27/2008

Judges

• Before MARY M. SCHROEDER, ANDREW J. KLEINFELD and CARLOS T. BEA, Circuit Judges.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Robert J. Henry, Lasher, Holzapfel, Sperry & Ebberson, PLLC, Seattle, WA, for the appellants.


• For Appellees:
  
• John A. Dudeck, Jr., Tax Division, U.S. Department of Justice, Washington, DC, for the appellee.