MARKEY, Chief Judge.
CIM International (CIM), alleged owner of an aircraft, appeals the grant of summary judgment upholding the seizure and sale of the aircraft in satisfaction of tax liens against Austin Milling Co., a Nevada Corporation (Austin), a third party taxpayer. We reverse and remand.
Background
The appeal being from a summary judgment, the facts set forth in the affidavits of record must be accepted as true.
On July 7, 1976...
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