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BLACHY v. BUTCHER

Nos. 99-1185, 99-1492, 99-1523.

221 F.3d 896 (2000)

Jobst W.F. BLACHY, et al., Plaintiffs-Appellees, v. Robert E. BUTCHER and Rosemary Butcher, co-personal representatives of the estate of Alexander Michael Butcher, deceased; Rosemary Butcher, individually; Little Traverse Development Company, a Michigan corporation; H.C. Development Company, a Michigan corporation, Defendants-Appellants (99-1185/99-1492), United States of America, on behalf of the Internal Revenue Service, Defendant-Appellant (99-1523).

United States Court of Appeals, Sixth Circuit.

Decided and Filed: July 21, 2000

Attorney(s) appearing for the Case

Robert E. Butcher (argued and briefed), Trenton, MI, Joan I. Oppenheimer (argued), United States Department of Justice, Appellate Section Tax Division, Washington, D.C., for Appellants.

Jeffrey G. Raphelson (argued and briefed), Bodman, Longley & Dahling LLP, Detroit, MI, for Appellees.

Alice L. Ronk (briefed), William S. Estabrook (briefed), United States Department of Justice, Appellate Section Tax Division, Washington, D.C., for Appellants.

Before: WELLFORD, SILER, and GILMAN, Circuit Judges.

GILMAN, J., delivered the opinion of the court, in which WELLFORD, J., joined. SILER, J. (pp. 912-13), delivered a separate opinion concurring in part and dissenting in part.

OPINION

GILMAN, Circuit Judge.

Even a diabolical bar examiner would be reluctant to impose this case's complex mixture of subject matter jurisdiction, fraud, real estate, marital property, bankruptcy, tax liens, contributory negligence, equitable remedies, and civil procedure...

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