Legal Opinion
Andrew B. Johnson, Individually and as Personal Representative of the Estate of Andrew Walfrid Johnson, and Joan M.M. Kuder v. United States
Court of Appeals for the Eighth Circuit
Decided August 20, 1986No. 85-5350PublishedCited by 1 opinion
1Opinion of the Court
BATTEY, District Judge.
The United States of America filed this appeal from the district court’s1 judgment which held that a forfeiture of a vendee-taxpayer’s interest in real property pursuant to a statutory cancellation of a contract for deed extinguished federal tax liens against the vendor perfected prior to forfeiture. Jurisdiction is conferred on this court by 28 U.S.C. § 1291. For the reasons set forth below, we affirm.
1. BACKGROUND
This is a quiet title action involving real property in Hennepin County, Minnesota. On June 11, 1981, appellees Johnson and Kuder (sellers) sold the property…
2Cases cited7 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- United States v. BrosnanSupreme Court of the United States · 1960
- Romain v. Pebble Creek PartnersSupreme Court of Minnesota · 1981
- Henry G. Runkel, Jr., Trustee of the Estate of Henry G. Runkel and of the Estate of Rosalie H. Runkel v. United StatesCourt of Appeals for the Ninth Circuit · 1975
- Hedlund v. BrellenthinDistrict Court, W.D. Washington · 1981
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3Cited by1 opinion
- Andrew B. Johnson, Individually and as Personal Representative of the Estate of Andrew Walfrid Johnson, and Joan M.M. Kuder v. United StatesCourt of Appeals for the Eighth Circuit · 1986