Legal Opinion
Sessler v. United States
Court of Appeals for the Ninth Circuit
Decided October 28, 1993No. Nos. 92-55031, 92-55042PublishedCited by 20 opinions
1Opinion of the Court
KOZINSKI, Circuit Judge:
Appellants, innocent third-party purchasers, challenge an IRS levy on their property because the Service did not give them timely notice of intent to levy. See 26 U.S.C. § 6331(d). We consider whether we have jurisdiction to resolve their claim.
I. Facts
In 1988, Robert and Natalie Sessler bought 70 acres of land from Robert Roy Granicy and his brother, who inherited it from their father. Unbeknownst to the Ses-slers, after Granicy Senior died, Robert Roy, who was also the executor, failed to pay the special estate tax; a lien in the amount of the unpaid tax attached to…
2Cases cited8 opinions
- Cottage Savings Assn. v. CommissionerSupreme Court of the United States · 1991
- Ronald James, and Kay James v. United StatesCourt of Appeals for the Tenth Circuit · 1992
- Earl Winebrenner v. United StatesCourt of Appeals for the Ninth Circuit · 1991
- Thomas Jerry Myers v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- E.J. Friedman Company, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1993
3 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Fidelity and Deposit Company of Maryland v. City of Adelanto United States Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1996
- Pentax Corp. v. MyhraCourt of Appeals for the Ninth Circuit · 1995
- United States v. Nye CountyCourt of Appeals for the Ninth Circuit · 1999
- United States v. Universal Fruits and Vegetables Corporation David Pai, AKA Shih Wei Pai Jason Pai, AKA Chung Sheng PaiCourt of Appeals for the Ninth Circuit · 2004
- Ralph H. Davis Evelyn Davis, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
15 more not listed; retrieve them via the Exa API.