Berkshire Bank v. Town of Ludlow

STAHL, Circuit Judge.

This appeal presents the question of whether a company that owned a particular parcel of land was the “nominee” of a delinquent taxpayer for purposes of a federal tax lien that attached to all of the taxpayer’s property. We conclude that it was and therefore affirm the district court’s grant of summary judgment in favor of the United States.

William A. Livermore owned approximately fifteen acres of undeveloped land in Ludlow, Massachusetts. In August 2005, the Town of Ludlow (Ludlow) approved Livermore’s plan to divide the property into eleven lots and turn it into a…