Markham, etc v. Fay

BOWNES, Senior Circuit Judge.

Appellant Claire M. Fay (“Fay”), in her capacity as trustee of three trusts, appeals the magistrate judge’s ruling that a federal tax lien upon her individual property extends to the entire assets of the trusts. Fay contends that the magistrate judge erred because the property of the trusts would not be considered her own under Massachusetts law. Fay also raises federal statutory and constitutional issues, contending that Appel-lee Internal Revenue Service (“IRS”) does not have a valid lien upon the trust property because it failed to comply with statutory notice…