Pia v. United States
United States Court of Claims
1Opinion of the Court
OPINION
MEROW, Judge:
This case comes before the court on cross-motions for summary judgment. Josie C. Pia, plaintiff, as trustee for Jack Massengale, seeks recovery from actions taken by the United States, Internal Revenue Service (IRS).
Facts
The dispute arises out of an April 22, 1981 tax sale of real property in which the defendant sold the residence of a delinquent taxpayer at a public auction to plaintiff for $28,000. Prior to the sale the IRS issued a formal notice of public auction sale which read, in pertinent part:
Title Offered:
Only the right, title, and interest of James & Mary J.…
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