Jenkins v. Edelhertz

Hines, Justice.

This is an appeal from a final judgment and order approving and adopting the report of the special master in this action to quiet title to real property, which was seized and sold by the United States Internal Revenue Service (IRS) for the nonpayment of federal income taxes. The sole issue is the propriety of the tax sale conducted outside the county where the property is located. Finding no showing that the sale violated the “place of sale” provisions of the United States Internal Revenue Code, 26 USC § 6335 (d), or the Code of Federal Regulations, 26 CFR § 301.6335-1 (c) (1),…