Fidelity National Title Insurance Company Philip Ruiz v. United States of America Department of the Treasury Internal Revenue Service

FERNANDEZ, Circuit Judge:

Fidelity National Title Insurance Company and Phillip Ruiz (collectively referred to as “Ruiz”) appeal the district court’s grant of summary judgment in favor of the United States Internal Revenue Service (“IRS”). The district court ruled that the IRS had a legitimate tax lien on Ruiz’ property. The court further held that Ruiz could not establish any priority over the IRS’ lien under a theory of equitable subro-gation. We affirm.

BACKGROUND FACTS

The property at issue in this case is located in West Covina, California. In 1979, the property was owned by Patrick and…