Legal Opinion

Southern Bank of Lauderdale County v. Internal Revenue Service, United States of America, Mid-State Homes, Inc. v. United States

Court of Appeals for the Eleventh Circuit

Decided September 13, 1985No. 84-7280, 84-7501PublishedCited by 22 opinions

1Opinion of the Court

CLARK, Circuit Judge:

These two cases, which were consolidated for oral argument purposes, present questions about the federal tax lien and the notice provisions of 26 U.S.C. § 7425(b). In both cases the district court granted summary judgment in favor of the appellees Southern Bank of Lauderdale County (Southern Bank) and Mid-State Homes, Inc. (Mid-State). For the reasons discussed below, we reverse.

1. FACTS

The facts in both cases are undisputed. The appellees, Southern Bank and Mid-State, obtained their respective interests in the property by either the assignment or execution of mortgages…

2Cases cited15 opinions

  1. Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
  2. United States v. Kimbell Foods, Inc.Supreme Court of the United States · 1979
  3. Aquilino v. United StatesSupreme Court of the United States · 1960
  4. United States v. RodgersSupreme Court of the United States · 1983
  5. United States v. BessSupreme Court of the United States · 1958

10 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. Haas v. Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1994
  2. In the Matter Of: John Davis Orr, Debtor. Internal Revenue Service v. John Davis OrrCourt of Appeals for the Fifth Circuit · 1999
  3. United States v. PolkCourt of Appeals for the Ninth Circuit · 1987
  4. United States v. State of ColoradoCourt of Appeals for the Tenth Circuit · 1989
  5. First American Title Insurance Co. v. United StatesCourt of Appeals for the First Circuit · 1988

17 more not listed; retrieve them via the Exa API.

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