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TKB INTERN., INC. v. U.S.

Nos. 91-55685, 91-55814.

995 F.2d 1460 (1993)

TKB INTERNATIONAL, INC., Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant. TKB INTERNATIONAL, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 3, 1993.

Attorney(s) appearing for the Case

Gary R. Allen and Kenneth L. Greene, Deputy Attys. Gen., Tax Div., Washington, DC, for defendant-appellant-cross-appellee.

David A. Stall, Callahan & Gauntlett, Irvine, CA, for plaintiff-appellee-cross-appellant.

Before: WALLACE, Chief Judge, TROTT and T.G. NELSON, Circuit Judges.

TROTT, Circuit Judge:

This case presents the interesting question of whether a federal tax lien on real property, filed in the proper location but outside the property's direct chain of title, is valid under 26 U.S.C. § 6323(f)(4) as against a subsequent purchaser for value who took the property with actual knowledge of the tax lien. We affirm the district court and hold that under this particular statutory scheme, the tax liens in this case are not valid as...

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