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PATE v. U.S. DEPT. OF TREASURY I.R.S.

No. 90-7095.

949 F.2d 1059 (1991)

Helen PATE; William Whitfield Pate; Julia Ruth Pate; Kirksey McCord Pate, Plaintiffs-Appellants, v. UNITED STATES of America, DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE, Defendant-Appellee.

United States Court of Appeals, Tenth Circuit.

November 20, 1991.

Attorney(s) appearing for the Case

G. Michael Blessington, Oklahoma City, Okl., for plaintiffs-appellants.

Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, William S. Estabrook and Jordan L. Glickstein, Attys., Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before LOGAN, MOORE and BALDOCK, Circuit Judges.

LOGAN, Circuit Judge.

Plaintiffs, the wife and children of Whit Pate, appeal from an adverse judgment entered by the district court on cross-motions for summary judgment in this quiet title action. The gravamen of the action concerns the validity of certain tax liens asserted against plaintiffs' property, which derive exclusively from the admitted tax liability of Whit Pate.1

The stipulated facts underlying the district court's...

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