Carr Enterprises, Inc. v. United States

MEMORANDUM OPINION

DONALD J. PORTER, District Judge.

CASE SUMMARY

Plaintiff, a South Dakota corporation, brought this case 1 as a quiet title action, contending that the federal tax liens on property owned by plaintiff were invalid because the liens — based on tax assessments against plaintiff’s principal stockholders— were created after its stockholders had transferred the property to plaintiff. Defendant United States asserted a counterclaim, seeking to have the transfer of the property to plaintiff by its stockholders declared a fraudulent conveyance under South Dakota law. Having considered…