Legal Opinion

Miller v. United States

District Court, M.D. Tennessee

Decided May 6, 1992No. 3:92-0028Published

1Opinion of the Court

ORDER AND JUDGMENT

WISEMAN, District Judge.

This matter came before the Court upon a motion by the plaintiffs for summary judgment pursuant to. F.R.Civ.P. Rule 56. The essential question to be decided is whether the United States Internal Revenue Service (hereinafter referred to as “IRS”) perfected hens in five specified parcels of real property located- in Davidson County, Tennessee, by virtue of notices of federal tax hens filed in Office of the Register of Davidson County, Tennessee, on June 11, 1990.

The plaintiffs maintain that documents of record with the Office of the Register of Davidson…

2Cases cited11 opinions

  1. Aquilino v. United StatesSupreme Court of the United States · 1960
  2. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
  5. Coca-Cola Bottling Company of Tucson, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964

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