Kinderhill Select Bloodstock, Inc. v. United States

MEMORANDUM, DECISION & ORDER

McAVOY, Chief Judge.

I. BACKGROUND

On August 17, 1993, agents of the Internal Revenue Service (“IRS”) seized four thoroughbred horses allegedly owned by the plaintiffs as a levy for back taxes owed by the Kinderhill Investment Company, Inc. (“Kinderhill Investment”). Three of the horses currently go by the names of M.J. Bean, Señorita Constanza, and Malicious (formerly Hardly Risen), and the fourth horse is an unnamed filly. Plaintiffs allege that Kinderhill Investment has no interest in these horses with the possible exception of M.J. Bean. Plaintiff Constance Moss…