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ROLAND v. U.S.

No. 87-2246.

838 F.2d 1400 (1988)

Scott Lynn ROLAND, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

March 8, 1988.

Attorney(s) appearing for the Case

Frank D. Moore, Cooper, Tex., for plaintiff-appellant.

Janet A. Bradley, Michael L. Paup, Chief, Appellate Section, Tax Div., Roger M. Olsen, Asst. Atty. Gen., Dept. of Justice, William S. Estabrook, William S. Rose, Jr., Acting Asst. Atty. Gen., Washington, D.C., for defendant-appellee.

Before TIMBERS, KING, and HIGGINBOTHAM, Circuit Judges.

TIMBERS, Circuit Judge:

Scott Lynn Roland ("Scott") appeals from a judgment entered February 12, 1987 in the Eastern District of Texas, Judith K. Guthrie, Magistrate, holding that the Internal Revenue Service rightfully could levy on real property fraudulently conveyed to Scott by his parents to satisfy back taxes owed by his parents. Scott claims that, at the time of the alleged fraudulent transfer, the IRS was not a

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