Acton Ltd. v. Harsh

MEMORANDUM **

The district court properly granted summary judgment to the Internal Revenue Service (“IRS”) in the Nevada quiet title action brought by Acton Limited (“Acton”). Even assuming that the original assignment from Edward and Ethlyn Harsh to the Edward J. Harsh Family Trust (the “Trust”) described the land sales contract with Gary and Anita O’Brien (the “O’Brien Contract”), it conveyed only a “beneficial interest” in such contract. This term refers to the “profit, benefit or advantage resulting from a contract or the ownership of an estate, as distinct from legal ownership or…