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FIRST AMERICAN TITLE INS. CO. v. U.S.

No. 05-35520.

520 F.3d 1051 (2008)

FIRST AMERICAN TITLE INSURANCE COMPANY; Commonwealth Land Title Insurance Company; Chicago Title Insurance Company, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed March 27, 2008.

Attorney(s) appearing for the Case

Robert J. Henry, Lasher, Holzapfel, Sperry & Ebberson, PLLC, Seattle, WA, for the appellants.

John A. Dudeck, Jr., Tax Division, U.S. Department of Justice, Washington, DC, for the appellee.

Before MARY M. SCHROEDER, ANDREW J. KLEINFELD and CARLOS T. BEA, Circuit Judges.

OPINION

KLEINFELD, Circuit Judge:

This is a tax collection case about a third party challenge to a tax assessment and lien on an earlier owner's property.

FACTS

In 1991, Penny Jensen's mother, Roberta Smith, died, and Jensen was named the personal representative of her mother's estate. The estate consisted of three houses and the stock of a corporation that owned a hamburger drive-in (Frisko Freeze, Inc.).

The estate...

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