Peggy Ann Schaefer Spotts v. United States

OPINION

BOYCE F. MARTIN, JR., Circuit Judge.

Peggy Spotts brought this quiet title action seeking to remove a nominee federal tax lien filed by the Internal Revenue Service for taxes owed by her former husband, Ray Spotts. The district court denied Peggy Spotts’s motion for summary judgment and granted summary judgment in favor of the Service. Peggy Spotts timely appealed.

The district court made the following statement of facts:

The case sub judice is a quiet title action filed in the Jessamine County Circuit Court brought under 28 U.S.C. § 2410, seeking the removal of the nominee tax lien filed…