Ballinger v. Geithner

ORDER

In this wrongful-levy action under 26 U.S.C. § 7426, Dennis Ballinger, Sr., seeks to enjoin the Internal Revenue Service from foreclosing liens recorded on his property in Galesburg, Illinois, to satisfy the previous owners’ federal tax liability. Alternatively, he seeks a larger slice of the sale proceeds than the IRS thinks he is entitled to. He appeals from a district court order denying him relief. Because Ballinger acquired the property subject to valid federal tax liens, we affirm.

According to the parties’ stipulated facts, the parcel’s previous owners failed to pay their 2003 real…