United States Ninth Circuit
Fourth Investment LP v. US, 11-56997
The district court's decision denying plaintiffs' quiet title claims to remove federal tax liens encumbering their real properties and upholding the validity of tax liens filed by the Internal Revenue Service is affirmed, where: 1) California law unambiguously recognizes the existence of nominee ownership; and 2) applying criteria set forth in relevant federal cases, the district court properly concluded that plaintiffs held legal title to the San Diego properties as nominees of the taxpayers.
Appellate Information
- Decided 06/13/2013
- Published 06/13/2013
Judges
- SMITH
Court
- United States Ninth Circuit