Baum Hydraulics Corp. v. United States

FINDINGS OF FACT AND CONCLUSIONS OF LAW

KOPF, District Judge.

This is an action brought pursuant to 28 U.S.C. § 2410 to determine whether the Internal Revenue Service (“IRS”) has issued a valid lien against plaintiff Baum Hydraulics Corporation (“Baum-Nebraska” 1 ). Following a bench trial on the merits of this case, I now issue my findings of fact and conclusions of law in accordance with Federal Rule of Civil Procedure 52(a). 2

I. FINDINGS OF FACT

In May 1991, the IRS began an examination regarding unpaid estate taxes and estate income tax liabilities relating to Sloan Allen, who died on March…