EC TERM OF YEARS TRUST v. U.S.

No. 05-1541.

127 S.Ct. 1763 (2007)

550 U.S. 429

167 L.Ed.2d 729

EC TERM OF YEARS TRUST, Petitioner, v. UNITED STATES.

Supreme Court of United States.

Decided April 30, 2007.


Attorney(s) appearing for the Case

Francis S. Ainsa, Jr. , El Paso, TX, for petitioner.

Deanne E. Maynard , Washington, DC, for respondent.

Francis S. Ainsa, Jr. , Ainsa Hutson, L.L.P., Attorneys at Law, El Paso, TX, for Petitioner.

Paul D. Clement , Solicitor General, Counsel of Record, Eileen J. O'Connor , Assistant Attorney General, Thomas G. Hungar , Deputy Solicitor General, Deanne E. Maynard , Assistant to the Solicitor General, Bruce R. Ellisen , Teresa T. Milton , Attorneys Department of Justice, Washington, D.C., for respondent.


This is a challenge to the Internal Revenue Service's levy upon the property of a trust, to collect taxes owed by another, an action specifically authorized by 26 U.S.C. § 7426(a)(1), but subject to a statutory filing deadline the trust missed. The question is whether the trust may still challenge...

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