United States v. Solheim

STUART, Senior District Judge.

We are called upon to determine whether the taxpayer’s renunciation, under state law, of his interest in a trust extinguished a federal tax lien attached to the interest under 26 U.S.C. § 6321 (1988). The district court1 held that the taxpayer’s renunciation did not extinguish the lien. Upon the taxpayer’s appeal, we affirm.

I

The taxpayer, Frederick S. Solheim, was the beneficiary of a trust created by his father, Selmer A. Solheim. The trust was funded in 1980 when taxpayer’s mother, Ruth M. Solheim, renounced her interest in a prior trust, causing the assets of…