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TITLE INS. CO. OF MINNESOTA v. I.R.S. OF U.S.

No. 91-1063.

963 F.2d 297 (1992)

TITLE INSURANCE COMPANY OF MINNESOTA, Plaintiff-Appellee, v. INTERNAL REVENUE SERVICE OF the UNITED STATES, Defendant-Appellant, Gerald Swanson, Defendant.

United States Court of Appeals, Tenth Circuit.

April 28, 1992.

Attorney(s) appearing for the Case

John N. Dahle of Grant McHendrie, P.C. (Walter J. Downing of Grant McHendrie, with him on the brief), Denver, Colo., for plaintiff-appellee.

Kent L. Jones (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, William S. Estabrook, and Robert L. Baker, Attys., Tax Div., Dept. of Justice, of counsel: Michael J. Norton, U.S. Atty., with him on the brief), Washington, D.C., for defendant-appellant.

Before BRORBY and McWILLIAMS, Circuit Judges, and ALLEY, District Judge.

McWILLIAMS, Circuit Judge.

This case concerns the validity of a certificate of redemption executed by the Internal Revenue Service (IRS) in connection with a state foreclosure of real property located in Adams County, Colorado. The district court held that the certificate of redemption was invalid under both federal and state law.

The case was presented to the district court on stipulated facts. From the stipulation we learn that Lynn Stanley Olsen and Judith...

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