Nelda Huebner Leggett, in the Matter of the Estate of Nelda Huebner Leggett, Deceased v. United States v. Patricia Huebner Schuette

JERRY E. SMITH, Circuit Judge:

In this tax case, we review a judgment that Patricia Huebner Schuette had a state property interest in property bequeathed to her by her aunt, despite the fact that she had filed a timely disclaimer and never took possession of, or exercised control over, the property. The district court held that a federal tax lien had attached to the property and the disclaimer was ineffective. We reverse.

I

The relevant facts are not in dispute. In 1995, Schuette owed the Internal Revenue Service (“IRS”) nearly $20,000. In May 1995, Schuette’s aunt, Nelda Leggett, died testate,…