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KIVEL v. U.S.

No. 87-6347.

878 F.2d 301 (1989)

Joseph KIVEL; Marilyn B. Mansour, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Submitted March 7, 1989.

Decided June 26, 1989.

Attorney(s) appearing for the Case

Lawrence R. Lieberman, Levinson & Lieberman, Beverly Hills, Cal., for plaintiffs-appellants.

Gary R. Allen, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before BROWNING, SCHROEDER and NOONAN, Circuit Judges.

NOONAN, Circuit Judge:

Joseph Kivel and Marilyn B. Mansour (the plaintiffs) brought suit under 26 U.S.C. § 7426(a)(1) and (b)(1) seeking relief from the seizure of their property by the Internal Revenue Service. The case turns on what, under federal tax law, is "a reasonable inspection" of the public index of deeds to real property in Orange County, California. The district court gave judgment in favor of the United States. We affirm.

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