Legal Opinion
Tkb International, Inc. v. United States of America, Tkb International, Inc. v. United States
Court of Appeals for the Ninth Circuit
Decided June 3, 1993No. 91-55685, 91-55814PublishedCited by 37 opinions
1Opinion of the Court
TROTT, Circuit Judge: •
This case presents the interesting question of whether a federal tax lien on real property, filed in the proper location but outside the property’s direct chain of title, is valid under 26 U.S.C. § 6323(f)(4) as against a subsequent purchaser for value who took the property with actual knowledge of the tax lien. We affirm the district court and hold that under this particular statutory scheme, the tax liens in this case are not valid as against the subsequent purchaser who took the property with actual knowledge.
I
The real property involved in this case is located at 760…
2Cases cited21 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- United States v. RodgersSupreme Court of the United States · 1983
- Slodov v. United StatesSupreme Court of the United States · 1978
- United States v. Gilbert Associates, Inc.Supreme Court of the United States · 1953
16 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- Rosario Gutierrez v. Jo Anne Barnhart, Commissioner, Social Security AdministrationCourt of Appeals for the Ninth Circuit · 2001
- In Re Billie Vester Rasbury, Debtor. Billie Vester Rasbury Bill's Forestry Service, Inc. v. Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1994
- In Re Cascade Roads, Inc., Debtor. United States of America v. Peter H. Arkison, TrusteeCourt of Appeals for the Ninth Circuit · 1994
- United States v. McCombsCourt of Appeals for the Second Circuit · 1994
- UNITED STATES v. McCOMBSCourt of Appeals for the Second Circuit · 1994
32 more not listed; retrieve them via the Exa API.