Federal Tax Lien Attachment

13 Florida cases classified under this topic · sorted by citation count · browse and sort

• Tillery v. Parks
  630 F.2d 775· 10th Cir.· 1980-09-09 ·cited 12×
  Federal tax liens arising from one spouse's tax liability may attach to that spouse's interest in the couple's homestead property in Oklahoma.
• United States v. Hubbell
  323 F.2d 197· 5th Cir.· 1963-09-24 ·cited 12×
  A federal tax lien attaches to a taxpayer's right of action for a tort, even if unliquidated, at the time the cause of action arises, and therefore predates any subsequent assignment of that claim.
• Bigheart Pipeline Corp. v. The United States (Internal Revenue Service)
  835 F.2d 766· 10th Cir.· 1987-12-22 ·cited 10×
  A federal tax lien attaches to the proceeds from oil produced from a leasehold, even if the leaseholder's interest was contingent at the time the lien attached and the oil was produced by a subsequent assignee.
• Runkel v. United States
  527 F.2d 914· 9th Cir.· 1975-12-09 ·cited 10×
  A declaration of forfeiture under a Washington real estate sales contract is not a 'sale' under 26 U.S.C. § 7425(b), and therefore does not require notice to the government to extinguish federal tax liens, provided the seller lacked actual notice of the liens.
• In re Terwilliger's Catering Plus, Inc. v. United States
  911 F.2d 1168· 6th Cir.· 1990-08-13 ·cited 9×
  The state's retained interest in a liquor license, including the right to demand payment of taxes as a condition of transfer, is a property interest that limits the debtor's estate's interest in the license.
• Tony Thornton Auction Serv., Inc. v. United States
  791 F.2d 635· 8th Cir.· 1986-05-21 ·cited 7×
  Federal tax liens for unpaid employment taxes attached to proceeds from the sale of property held by entirety because both spouses were jointly liable for the taxes, and the notices of lien were sufficient to establish validity against a judgment lien creditor.
• United States v. Safeco Ins. Co. OF Am., Inc.
  870 F.2d 338· 6th Cir.· 1989-03-16 ·cited 4×
  A federal tax lien attaches to a taxpayer's accrued but unpaid salary, even if disbursement is restricted by court order, because such accrued salary constitutes a property interest under federal law.
• United States v. Ruff
  179 B.R. 967· M.D. Fla.· 1995-01-09 ·cited 2×
  A taxpayer's earned but unpaid commission, even if subject to bankruptcy court approval for payment, constitutes 'property or rights to property' subject to IRS levy.
• Coleman R. Rosenfield and Telsa Rosenfield v. Rosenfield
  404 So. 2d 188· Fla. 4th DCA· 1981-09-30 ·cited 2×
  The trial court had the authority to order satisfaction of a Federal tax lien from the proceeds of a partition sale, and the lien attached before the entireties estate was created.
• Metro. Dade Cnty. v. United States
  635 F.2d 512· 5th Cir.· 1981-01-30 ·cited 2×
  Confiscated funds declared contraband and escheated to the state under Florida law at the time of seizure, meaning no property interest remained for the IRS tax levy to attach.
• Katsaris v. United States
  499 F. Supp. 282· N.D. Fla.· 1980-09-15 ·cited 1×
  The IRS tax lien attached only to the money found in Acosta's wallet, not the larger sum abandoned by Acosta to avoid incriminating himself in a drug prosecution.
• United States v. Solheim
  953 F.2d 379· 8th Cir.· 1992-01-07
  A federal tax lien attached to a taxpayer's interest in a trust under 26 U.S.C. § 6321, and the taxpayer's subsequent renunciation of that interest under state law was ineffective to extinguish the lien.