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FOURTH INV. LP v. U.S.

Nos. 11-56997, 11-57009.

720 F.3d 1058 (2013)

FOURTH INVESTMENT LP, a California limited partnership, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. Leeds, LP, a California limited partnership, Plaintiff-Appellant, v. United States of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed June 13, 2013.

Attorney(s) appearing for the Case

Wendy C. Lascher (argued), Ferguson Case Orr Paterson LLP, Ventura, CA, for Plaintiffs-Appellants.

Thomas J. Clark (argued), Supervising Attorney, and Bethany B. Hauser , United States Department of Justice, Tax Division, Washington, D.C., for Defendant-Appellee.

Before: MILAN D. SMITH, JR. and MARY H. MURGUIA, Circuit Judges, and JACK ZOUHARY, District Judge.

OPINION

M. SMITH, Circuit Judge:

Plaintiffs-Appellants Leeds, LP (Leeds) and Fourth Investment, LP (Fourth Investment) (sometimes collectively, Appellants) brought quiet title actions challenging tax liens filed by the Internal Revenue Service (IRS) against certain commercial and residential properties located in San Diego, California, to which Appellants hold legal title. The tax liens arose from assessments against taxpayers Susanne and Don Ballantyne...

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