J. BLAINE ANDERSON, Circuit Judge:
Joseph E. Simon and John P. Simon appeal the district court's summary judgment in favor of the United States. The district court held that the Simons' interest in property they had purchased at a state tax sale was subordinate to a federal tax lien. We affirm.
I. BACKGROUND
The Simons purchased real property at a Los Angeles County tax auction sale. The property had been deeded to the State of California because...
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