Edith Libutti, Doing Business as Lion Crest Stable, a Sole Proprietorship v. United States

BLOCK, District Judge:

“Withdraw, my lord; I’ll help you to a horse.” 1

The United States appeals from a judgment of the District Court for the Northern District of New York (McAvoy, J.) vitiating a tax levy placed by the Internal Revenue Service (“IRS”) on a race horse named Devil His Due as part of its ongoing effort to collect over four million dollars of unpaid income taxes from Robert LiButti (“Robert”). The district court found, after a bench trial, that Robert’s daughter, Edith LiButti (“Edith”), “was the sole owner of Devil His Due at the time it was levied upon” and that the government…