Real Estate Equity Strategies, LLC v. Internal Revenue Service

COLLOTON, Circuit Judge.

Real Estate Equity Strategies, LLC (REES), brought this quiet title action against the Internal Revenue Service (IRS), alleging that the IRS’s redemption on a parcel of property was untimely and therefore invalid. The district court 2 granted the IRS’s motion for summary judgment and dismissed the case, determining that REES lost its ability to challenge the IRS’s redemption when it failed to tender sufficient funds in its own attempted redemption. We affirm.

I

On January 27, 1990, James and Kathryn Moore purchased a parcel of property located at 14909 Crown Drive,…