Mayer-Dupree v. Internal Revenue Service

1993 U.S. App. LEXIS 24639 (1993)

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Mayer-Dupree v. Internal Revenue Service

United States Court of Appeal for the Tenth Circuit
1993 U.S. App. LEXIS 24639 (1993)

CS

Facts

Mayer-Dupree (plaintiff) purchased a vehicle from a delinquent taxpayer in 1986. Although Mayer-Dupree alleged that she received the certificate of title, she failed to register the title with the state government. The vehicle was the subject of federal tax liens against the seller that accrued in 1985 and were noticed in 1988 and 1990. In 1991, the Internal Revenue Service (IRS) (defendant) seized the vehicle in satisfaction of the liens. After the seizure, Mayer-Dupree registered the title. Mayer-Dupree filed a wrongful levy action against the IRS. The IRS petitioned for summary judgement, and the district court dismissed the case. Mayer-Dupree appealed.

Rule of Law

Issue

Holding and Reasoning (Tacha, J.)

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