United States v. Ritter

CRAVEN, Circuit Judge:

In the district court, the United States sought to foreclose tax liens which encumber personalty allegedly belonging to the deceased taxpayer’s estate. The district court entered summary judgment against the United States, concluding that the property in question was not an asset of the estate since it had passed directly to the taxpayer’s heirs. We do not regard the court’s conclusion as a sufficient warrant for its result; and, for the reasons below, we reverse.

I

Upon the death of his grandmother, the taxpayer, Don McClintock Ritter, Jr., stood to receive outright Vioth…