Legal Opinion
Mary Joyce Thomson v. United States
Court of Appeals for the Eighth Circuit
Decided September 19, 1995No. 94-3861PublishedCited by 11 opinions
1Opinion of the Court
LOKEN, Circuit Judge.
In 1971, Douglas and Mary Thomson divorced. The divorce decree awarded Mary “exclusive use, ownership and possession” of their home, which they were purchasing under a contract for deed. The divorce decree was unrecorded when the Internal Revenue Service obtained a lien on all of Douglas’s property rights under 26 U.S.C. § 6321. The IRS levied on the home, and Mary commenced this wrongful levy action under 26 U.S.C. § 7426, claiming that she owns the home. After a bench trial, the district court held that the IRS prevails over Mary’s unrecorded ownership interest under…
2Cases cited19 opinions
- Aquilino v. United StatesSupreme Court of the United States · 1960
- United States v. RodgersSupreme Court of the United States · 1983
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- United States v. Randolph C. Fernon, Jr., Etc. And Susanna F. FernonCourt of Appeals for the Fifth Circuit · 1981
- Valley Finance, Inc. v. United StatesCourt of Appeals for the D.C. Circuit · 1980
14 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Fay E. Sams Money Purchase Pension Plan v. JansenCourt of Appeals of Kentucky · 1999
- In Re RobrockUnited States Bankruptcy Court, D. Minnesota · 2010
- United States v. David Gibbons, and Betty J. GibbonsCourt of Appeals for the Tenth Circuit · 1995
- In Re LowensteinUnited States Bankruptcy Court, D. Massachusetts · 2007
- Marshall v. MarshallDistrict Court, D. Minnesota · 1995
6 more not listed; retrieve them via the Exa API.