Nos. 96-1038, 96-1039.

140 F.3d 638 (1998)

Sandra L. CRAFT, Plaintiff-Appellant/Cross-Appellee, v. The UNITED STATES of America, acting Through the COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee/Cross-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided April 1, 1998.

Attorney(s) appearing for the Case

Jeffrey Alan Moyer (argued and briefed), Donovan, Love & Twinney, Grand Rapids, MI, for Plaintiff-Appellant/Cross-Appellee.

Gary R. Allen, Acting Chief, David English Carmack (argued and briefed), Sara S. Holderness (briefed), Marion E.M. Erickson, U.S. Department of Justice, Appellate Section Tax Division, Washington, DC, for Defendant-Appellee/Cross-Appellant.

Before: RYAN, SUHRHEINRICH, and COLE, Circuit Judges.

COLE, J., delivered the opinion of the court, in which SUHRHEINRICH, J., joined. RYAN, J. (pp. 645-649), delivered a separate concurring opinion.


COLE, Circuit Judge.

Sandra Craft appeals the district court's order granting summary judgment in favor of the United States, in which the district court found that a federal tax lien filed against the property of Sandra's husband for his individual unpaid tax liabilities attached to property held...

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